MANAGING RISK

FUEL QUALITY TESTING

INSTRUCTION MANUAL

DNV PETROLEUM SERVICES

CONTENTS

Welcome To The DNV Fuel Quality Testing ProgrammeIntroductionAnnex VI of MARPOL 73/78

Overview of the DNVPS samples

Procedures For SamplingSampling Sampling kitSampling deviceSafety considerations during samplingSampling procedureRequest to Witness Sampling FormContinuous-drip sampling Dividing the Sample evenly Sealing the bottlesInsert sample into Ziplock bagSample for supplierShip's retained sample MARPOL Annex VI sampleDespatching the sample Using correct colour labelsChief Engineer's introduction to ship's agentUrgent despatch by ship's agent

General Guidelines On BunkeringThe Bunker Delivery Note

Investigations and Sampling of Tanks and Fuel SystemsGeneral guidelinesTank and Fuel System SamplingSludge samplesCombustion deposit samples

Fuel System Check (FSC) Why Fuel System Check?Sampling and DistributionSampling ProcedureSafetyForwarding the samplesTesting & Reporting the samples

Guidelines on Interpreting Test ParametersDensity Viscosity WaterCarbon Residue Sulphur SedimentsAshCatalytic FinesElementsFlash PointCCAIFTIR scanning of MDO samples

MARPOL Annex VI servicesSulphur content testingVerification of fuel change-over proceduresOn board blending - Blend Optimisation Programme (BOP)

AppendicesMARPOL ANNEX VI Bunker Sample Record Guidelines (Proposed By DNVPS)Example -- MARPOL ANNEX VI Bunker Sample Record Form

DNVPS Guidelines For Issuing Note Of ProtestExample -- MARPOL ANNEX VI Note Of Protest

Eample - MARPOL ANNEX VI Bunker Sample Record

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Thank you for choosing DNV Petroleum Services (DNVPS) as your fuel management partner. We are committed to providing you with the best possible marine fuel management programme.

Our fuel quality testing (FQT) programme is considered to be a highly cost effective risk management tool in terms of safeguarding the ship and its crew from the adverse effects of poor fuel oil quality.

DNVPS introduced its FQT service in 1980 to meet the needs of a maritime community seriously concerned about the quality of bunkers in many of the world's ports. Over the years the problems encountered by shipowners and operators in the purchase and use of marine fuels have not diminished. Fuel quality has not improved and is in fact likely to get worse with the introduction of more severe cracking in the refining process. More and more crude oil is traded world-wide and it is now increasingly dif ficult to identi fy what in the past have been traditional sources of quality problems. It is therefore prudent to safeguard your vessel by constantly monitoring the quality of fuel received on board and ensuring that the fuel is not used until tested.

Plain SailingPlain Sailing

DNVPS fulfils the need for an independent international testing service which is credible both to shipowners and suppliers alike. Unlike some testing services which may only operate a single laboratory or none at all and therefore have to subcontract the fuel analysis, DNVPS operates five wholly-owned, specialised and accredited laboratories, dedicated to fuel analysis. These laboratories are strategically located in Oslo, Rotterdam, Singapore, Fujairah and Houston to ensure that samples from the ships will reach the appropriate DNVPS laboratory in the shortest possible time, thereby ensuring fast turnaround of test results and prompt technical advice. The laboratories, located in different time zones, are linked by a Wide Area Network and provide 24 hour service access and technical assistance. This special feature of our FQT programme is unequalled by other testing services.

Further, by working with the world's top courier companies, such as DHL, TNT and FedEx, your samples will be reliably handled throughout the delivery.

DNVPS laboratories and offices are manned by highly qualified technical advisers working across all time zones to provide you with round the clock assistance. Our online service, DataAccess, also lets you download your test reports directly from the Internet as soon as the results are available.

Using state of the art laboratory equipment and leveraging the cumulative in-depth knowledge and experience from extensive R&D as well as more than 800,000 samples tested to date, our marine fuel experts will ensure that you receive the best qualified advice available from our detailed fuel analysis reports and personal technical assistance.

With over 70 per cent market share in the bunker analysis business, DNVPS boasts an extensive monitoring network that can spot fuel quality problems in ports around the world. You will be immediately notified of these problems through our Bunker Alert and Bulletin service, exclusively available to members of the DNV FQT programme.

Combining DNVPS' timely Bunker Alerts and Bulletins, comprehensive test results and readily available technical advice, you can avoid or limit fuel-related engine damage and achieve substantial cost savings.

The procedures and documentation of DNVPS' fuel testing programme complies fully with Annex VI of MARPOL, and participation in this programme ensures that ships have access to compliant sampling equipment (sample bottles, seals, line samplers and cubitainers). Further, ship operators will have access to our bunker alerts and bulletins as well as comprehensive fuel oil quality statistics, all of which will provide ship operators with valuable assistance in their bunker management.

In addition to FQT, DNVPS also provides a whole range of other products and services, such as sampling kits, line samplers, portable laboratory kits, training videos, technical seminars, fuel system checks (FSC), blend optimisation programmes (BOP), Bunker Quantity Surveys (BQS), quarterly statistical publications of worldwide fuel quality and FuelWise, an online service offering real-time updates of bunker quality from virtually any supplier in the world.

DNVPS is also in the forefront of developing extended testing services such as fuel ignition analysis and advanced investigative analysis for detection of added substances and chemical wastes in marine fuels. These services are all conducted in-house, meaning that DNVPS is not dependent on sub-contractors' availability. Combined with extensive fuel knowledge and existing data, this has enabled us to develop unequalled experience in marine fuel analysis and interpretation of results. Additionally, DNVPS has access to the DNV network and range of advanced testing facilities, including the advanced materials laboratories in Oslo and Singapore.

Finally, DNVPS is also able to provide our customers with relevant information and assistance from DNV Maritime Industries (classification & maritime consultants), DNV Research, DNV Consulting and other business units within the DNV organisation.

As you embark on the DNV Fuel Quality Testing programme, please go through this Instruction Manual to ensure that your vessels take full advantage of the benefits offered by our programme.

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Introduction

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Annex VI of MARPOL 73/78

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Annex VI of MARPOL 73/78 “Regulations for the prevention of Air Pollution from ships” will enter into force on 19 May 2005, and will apply to all ships, fixed and floating drilling rigs and other platforms. Ships of 400 gross tons and above engaged in international voyages involving countries that have ratified the conventions are required to hold an International Air Pollution Prevention Certificate (IAPP Certificate) and will be subject to associated periodical surveys and port state controls.

This certificate must be provided onboard newbuildings keel-laid after 19 May 2005 upon delivery. For ships keel-laid before this date, the IAPP certificate must be on board at the first scheduled drydocking after 19 May 2005, but not later than 19 May 2008.

The implementation of Annex VI implies, among other things, that fuel quality and bunkering procedures will become a statutory requirement and be subject to surveys, both by flag states (normally delegated to classification societies) as well as port state control.

Details and explanations relating to documentary and procedural requirements are found in Resolution MEPC. 96(47) “Guidelines for the sampling of fuel for determination of compliance with Annex VI of MARPOL 73/78”. It should be noted that Intertanko has also issued a thorough and useful guide on MARPOL Annex VI. From a fuel quality perspective, the following requirements apply:

Regulation 18 Fuel oil quality:

Reg.18 requires that fuel oil supplied to ships is to be free from inorganic acids, or chemical wastes that could jeopardise the safety of the ship, cause harm to ship personnel, or which would contribute overall to additional air pollution.

Bunker delivery notes:It is a requirement that any fuel oil for combustion purposes delivered to and used onboard shall be recorded by means of a Bunker Delivery Note (BDN). This BDN is identical to the Bunker Delivery Receipt (BDR) or Bunker Receipt. A BDN shall therefore be presented for every barge delivery and for every fuel grade delivered.

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Further, Resolution MEPC.96(47) recommends that the seal number of the associated MARPOL Annex VI fuel sample is included in the BDN for cross-reference purposes.

The BDN is to be kept on board and readily available for inspection at all times. Both the ship and the supplier are required to retain the BDN for a period of three years after the fuel oil has been delivered on board.

MARPOL Annex VI fuel oil samples:Regulation 18 requires that every BDN is to be accompanied by a representative sample of the fuel oil delivered, taking into account the guidelines in Resolution MEPC.96(47).

On completion of the bunkering operation, the sample is to be sealed and signed by the supplier's representative and the receiving ship's master or officer in charge. This sample must be retained under the ship's control until the fuel oil has been substantially consumed, but in any case for a period of not less than 12 months from the time of delivery. Although MEPC.96(47) specifies that the volume of the sample bottle should be no less than 400 ml, Intertanko has recommended that the sample volume is not to be less than 750 ml due to the potential need for repetitive testing. The volume of the DNVPS sample bottle is in accordance with the Intertanko recommendation.

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The BDN is required to contain the following: Name and IMO number of receiving ship Bunkering port Date of commencement of bunkering Name, address, and telephone number of marine fuel oil supplier Product name Quantity (metric tons)

o 3 Density at 15 C (kg/m ) Sulphur content (% m/m)

A declaration signed and certified by the fuel oil supplier's representative that the fuel oil supplied is in conformity with regulations 14 and 18 (i.e. that the fuel supplied has a sulphur level as specified in the BDN and that the fuel is free from inorganic acid, does not include any added substance or chemical waste which either jeopardises the safety of ships, adversely affects the performance of the machinery, causes harm to personnel, or contributes overall to additional air pollution).0000000000000000000000000000000000000000000000000000

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As Annex VI specifies that the Annex VI sample is not to be used for commercial purposes, DNVPS recommends that for ships already participating in a fuel oil quality testing scheme, the Annex VI sample should be the fourth sample (in addition to the sample sent for lab testing, the sample given to the supplier, and the sample to be retained on board). The reason is that it is considered an advantage to always have a dedicated Annex VI sample onboard in case of port state controls. This is especially so in the event that the ship's retained sample has been sent ashore to settle a fuel quality dispute or for some other purposes.

Sampling procedures:Resolution MEPC.96(47) specifies in detail that the fuel sample is to be obtained at the receiving ship's inlet bunker manifold and is to be drawn continuously throughout the bunker delivery period. The term “continuously drawn” means a continuous collection of drip sample throughout the delivery of bunker fuel. Permitted sampling devices are further clarified as either manual valve-setting continuous-drip sampler (equivalent to the DNVPS line sampler), time-proportional automatic sampler, or flow-proportional automatic sampler.

The guidelines further specify that sample bottle labels are to contain the following information:

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On board bunkering procedures have to be amended to reflect the Annex VI requirements and this can be achieved by referring to the guidelines in this instruction manual.

DNVPS' line sampler, sample bottle labels and recommended procedures for sampling and sample preparation are in accordance with the above requirements.

Sample inventory:Resolution MEPC.96(47) also covers sample storage location. The samples are to be kept in a safe storage location, outside the ship's accommodation and where personnel would not be exposed to vapours which may be released from the samples. Further, the retained sample should be stored in a sheltered location preferably at a cool/ambient temperature, where it will not be subject to elevated temperatures or exposed to direct sunlight. On tankers, the cargo sample locker would be considered a suitable storage space. Alternatively, a locker with openings for adequate air flow may be considered, if it is located in a well-ventilated area of the engine room and at a safe distance from ignition sources and hot surfaces.

An inventory system (eg. record book) should also be developed to keep track of the retained samples. For your reference, DNVPS has enclosed a sample inventory record book guideline in this Instruction Manual.

Supplier's responsibility:While most IMO conventions place full responsibility on ships and the shipowners, Regulation 18 imposes a certain responsibility on the suppliers.

Annex VI of MARPOL also contains instruments to encourage port states to ensure that suppliers fulfil their obligations. Port states are required to:

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Notwithstanding the suppliers' responsibilities and the instruments available, previous experience from port state controls indicates that it is advisable for owners/managers themselves to ensure compliance. In order to safeguard the ship from the non-compliance it is recommended that a Letter of Protest is issued in case the suppliers fail to meet the requirements of Annex VI. A standard Annex VI Letter of Protest form is included in this Instruction Manual.

Maintain a register of local fuel oil suppliers;Ensure local suppliers provide the BDN and sample, certified by the fuel oil supplier that the fuel oil meets the requirements of regulations 14 and 18;Ensure local suppliers retain a copy of the BDN for at least three years for inspection and verification by the port State as necessary;Take appropriate action against fuel oil suppliers that have been found to deliver fuel oil that does not comply with the requirements stated on the BDN;Inform the Flag Administration of any ship receiving fuel oil found to be non-compliant with the requirements of regulations 14 or 18 of MARPOL Annex VI;Inform IMO for transmission to Parties to the Protocol of 1997 of all cases where fuel oil suppliers have failed to meet the requirements specified in regulations 14 or 18.

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Location at which, and the method by which, the sample was drawnBunkering dateName of bunker tanker/bunker installationName and IMO number of the receiving shipSignatures and names of the supplier's representative and the ship's representativeDetails of seal identificationBunker grade

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Regulation 14 - Sulphur Oxide (SOx) emissions from ships

It is expected that additional SECAs will be designated in the future and IMO has set forth certain criteria for designating such SECAs. It should however be noted that the amendment process within IMO may take considerable time. Ship operators should also be aware that the limitations in sulphur content applies to all marine fuel oils (heavy fuel oils, marine diesel oils and gas oils) and regardless of use on board (i.e. in combustion engines, boilers, gas turbines etc.).

Bunker specifications and contracts need to reflect required sulphur levels worldwide and in the SECAs if relevant to the ship's trading patterns. It is also imperative that the crew verifies that the sulphur content specified in the BDN is in accordance with the these specifications and contracts.

Change-over procedures:When approaching a SECA, the fuel must be changed over to fuel with sulphur content fuel not exceeding 1.5 % and this must be completed upon entry into the SECA.

For ships with standard fuel oil system configurations (one service tank and one settling tank), this will involve filling the settling tank with low sulphur fuel oil, adequate treatment and subsequent channelling of this fuel to the service tank, as well as flushing the fuel service piping systems to remove all fuel oil with sulphur level above 1.5 %.

Change-over procedures need to be developed and should specify the necessary precautions to be taken and the time needed for such change-over.

Additionally, the time and ship's positions at the start and completion of the change-over must be recorded in a logbook, together with details of the tanks involved and fuel used.

Although it is acknowledged that the engine room log books or the deck log books are most suitable for recording change-over, a record form guideline has been included in this Instruction Manual.

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When Annex VI of MARPOL enters into force on 19 May 2005, sulphur oxide (SOx) emissions from ships will be controlled by a 4.5% limit on sulphur content in marine fuel oils. The average sulphur content in fuels today is approximately 2.7 %.

Further, a 1.5% limit on the sulphur content of marine fuel oil will apply in designated SOx Emission Control Areas (SECAs). IMO has currently agreed on the designation of two SECAs:

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The Baltic Sea Area, which will come into force on 19 May 2006. The North Sea Area and the English Channel, which will not take effect until 19November 2007.

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Overview of DNVPS samples

The diagram below describes the purpose of the different fuel oil samples to be taken under the DNV Fuel Quality

Testing and Fuel System Check programmes, as well as the associated labels accompanying these samples.

Please note that each sample must be duly-filled and attached with security seals and the respective service labels.

MARPOL Annex VI sample

This sample is to be provided with the MARPOL Annex VI sample bottle label and security seal and is to be retained onboard for a minimum of 12 months or until the fuel has been substantially consumed.

Details pertaining to the MARPOL Annex VI sample and subsequent destruction or shipment need be recorded in a sample inventory log.

Sample to Lab

This sample is to be provided with the FQT sample bottle label and security seal and is to be sent to DNVPS laboratory for fuel quality testing.

The bottle is to be placed in Ziplock bag and carton together with Chief Engineers form and copy of Bunker Delivery Note and sent to the appropriate DNVPS laboratory in accordance with these instructions.

Ship's retained sample

This sample is to be provided with the FQT sample bottle label and security seal and is to be retained onboard.

In the event of a quality dispute, the sample may be required sent to a laboratory for testing in the presence of the parties involved in the dispute.

Supplier's sample

This sample is to be provided with the FQT sample bottle label and security seal and is to be given to the supplier.

If the supplier declines or discards the sample, make sure that this is recorded in the ship's log.

FSC sample

This sample is forchecking theefficiency of thefuel pre-treatmentsystem (see FuelSystem Check onpage 15). Affix the FSC sample bottle label and security seal to this sample, which is to be sent to the DNVPS laboratory for testing.

Place the bottle in a Ziplock bag before putting it in the FSC carton box provided. Dispatch the sample to the appropriate DNVPS laboratory in accordance with given instructions.

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PROCEDURES FOR SAMPLING

SAMPLINGThe importance of proper sampling cannot be over-emphasised, as the analysis results will be only as good as the sample that you have submitted.

Please ensure that your staff is fully conversant with both the sampling procedure recommended in this instruction manual and your company's fuel management practices.

DNVPS advocates Custody Transfer Sampling, which is also a requirement under the Singapore Code of Practice CP60. If your fuel has been purchased on FOB terms and delivered by barge or at the tank terminal, the DNVPS recommended location for Custody Transfer Sampling is on the ship's bunker manifold. Note that Resolution MEPC 96(47) referred to in Annex VI of MARPOL 73/78, also specifies that the representative sample is to be taken at the ship manifold. If there are technical reasons as to why you do not have a choice but to take a sample at the barge manifold or any other locations, such reasons should be recorded.

In order to obtain a representative sample of the fuel delivered to the ship, the sample has to be drawn continuously throughout the entire bunkering process. To achieve this, DNVPS strongly recommends that you use a DNVPS continuous drip line sampler, together with clean DNVPS cubitainers. The DNVPS line sampler can be sealed to prevent tampering during the sampling operation. Please note that the use of a continuous drip or auto-sampler is specified in Resolution MEPC 96(47).

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EASY

CUSTODY

TRANSFER

SAMPLING

EASY

CUSTODY

TRANSFER

SAMPLING

Sampling DevicePlease ensure that your vessel has a proper sampling device at the point of Custody Transfer, ie. at the ship's bunker manifold. Your sampling device and collection container must also be clean and ready for use. As a routine, clean the sampling device immediately after every bunkering to minimise the possibility of contamination by remaining fuel oil or cleaning solvents. If your vessel is not fitted with a proper sampling device, you will not be able to take a representative sample as required by Annex VI of MARPOL 73/78. We therefore strongly recommend that you place an order for a DNVPS Line Sampler. A brochure and an order form are enclosed in this manual.

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Sampling KitThe sampling kit contains :- Sampling bottles with caps IATA approved FQT shipping cartons IATA approved Fuel System Check carton Security seals Ziplock bags Labels for FQT Sample Bottles Labels for FSC sample bottles Labels for MARPOL sample bottles “For receipt only - source unkown” stamp “For volume and temperature only” stamp

One Instruction Manual, containing- FQT sampling instructions (incl. MARPOL Annex VI)- FSC sampling instructions- Line sampler brochure- Custody transfer brochure- MARPOL Annex VI sample inventory log guideline- MARPOL Annex VI letter of protest guideline- Air Courier Directory- Request to Witness Sampling Form- Chief Engineer's Report Form- Standard Pro Forma Invoice- Return Address Labels for sending fuel samples to the appropriate DNVPS Laboratory

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Sampling Procedures

Request To Witness Sampling Form It is the supplier's responsibility to provide a representative MARPOL sample, continuously drawn throughout the entire bunkering process. However, it is not considered feasible to take representative samples for fuel quality testing purposes and the MARPOL sample in parallel. Hence, the supplier should be encouraged to accept the practice of taking the MARPOL sample in conjunction with the sample for fuel quality testing.

Regardless of the supplier's preference, the ship crew as a precaution should always take their own MARPOL Annex VI sample as a fourth sample together with the other three fuel samples, in accordance with the instructions below.

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Continuous Drip Sampling Take a continuous drip sample by using the DNVPS Line Sampler. Adjust the needle valve to give a slow continuous drip throughout the whole bunkering period. Seal the needle valve with the security seal provided. Record the seal number to prevent any tampering. Collect approximately 5 litres of sample in the cubitainer. Both 5 - litre and 10 - litre cubitainers are supplied by DNVPS. If 5-litre cubitainers are used, precautions should be taken to prevent over - filling. Check that there is sufficient fuel sample in the cubitainer by the end of the bunkering. If you need to break the seal on the needle valve to make adjustments, you should invite the bunker barge Cargo Officer or his representative to be present when you adjust the drip and replace the security seal. Keep proper records in your ship's log if the invitation is declined and also when such adjustments took place.

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Invite the supplier's representative to witness the sampling procedures. Complete a 'Request to Witness Sampling' form and ensure that it is signed by both parties. Give the top copy to the supplier's representative. Retain the blue copy for your file.

If the supplier declines to attend the witnessing of sampling, you must note this in the ship's log-book there and then. Such a record can serve as contemporaneous evidence should a fuel quality dispute later arise. Please ensure that full information about the barge, cargo officer, supplier, time, date and circumstances etc, are recorded.

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Safety considerations during sampling

The following safety precautions should be taken during any sampling:

Protective equipment to be worn by personnel involved in the sampling H2S detection should be carried out periodically Spill prevention procedures should be adhered to Spill containment equipment should be available at the bunker manifold Regulations regarding the entry and equipment used in hazardous areas should be strictly observed Smoking and naked lights should be prohibited in the vicinity of potential oil vapor sources

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Dividing The Sample Evenly Cap the cubitainer and shake the content vigorously for about 10 minutes to mix the sample thoroughly. If bunkering in cold climates ensure that the sample collected in the cubitainer is warm enough to allow for shaking. Fill four(4) sample bottles 1/3 at a time. Make several passes to fill up the bottles equally, capping and re-shaking the cubitainer before each filling. This is to ensure that the sample is evenly distributed and the contents in each bottle is representative. In some cases, other parties may require samples for testing (e.g. both the owner and the charterer may be on the testing programme) and will require separate samples to be sent. In such cases additional samples should be taken as required. Fill the bottles up to the mark “FILL TO THIS LINE.” Stop at the line as shown in the diagram on the right.

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Sealing The Bottles Close the bottles tightly using the screw caps provided. Seal all the bottles and record all seal numbers on the Chief Engineer's report form. It is important also to record this information in the ship's log book. In addition, we strongly advise you to require that the supplier records all sample seal numbers in the BDN for cross-reference purposes. Complete three fuel quality testing sample bottle labelsand one MARPOL sample bottle label. Sign these labels in the presence of and jointly with, the supplier's representative.

Fix a label on each bottle.

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Do not sign any blank labels for the barge crew under any circumstances.

Caution: If you are offered a sample by the barge crew and have not witnessed correct sampling procedures pertaining to this sample, please use the rubber stamp provided in the kit to indicate “For Receipt Only, Source Unknown“ on the sample bottle.

Insert Sample Into Ziplock BagPut the bottle of sample to be sent for testing into the Ziplock bag to prevent any spillage. Gently squeeze the Ziplock bag to minimize any air content prior to sealing.The sample will be sent to the appropriate DNVPS Laboratory via courier once the correct colour label is used. See Courier despatch directory provided on which labels to use.

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Sample For SupplierHand one bottle to the Supplier's representative. If the supplier declines or discards the sample, make sure that this is recorded in the ship's log with full details of the person, barge supplier, time, date, incident, seal number of the sample etc. This information is essential for the purpose of collecting contemporaneous evidence in the event of a quantity or quality dispute at a later stage.

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Ship's Retained Sample It is very important to retain one bottle of sample onboard in a secure location as in most cases this may be the only sample left which represents the fuel delivered to your ship.

IMPORTANTIf this sample is eventually sent for testing, all parties involved or their representatives must be present to witness the breaking of the seals and the testing process.

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IMPORTANT : SHIP’S RETAINED SAMPLE MUSTBE KEPT IN A SECURE PLACE. IN CASE OFDISPUTE, SEAL IS TO BE BROKEN ONLY INPRESENCE OF ALL PARTIES CONCERNED.

MARPOL Annex VI sampleStore the MARPOL Annex VI sample, taken by the supplier or by the ship crew, onboard in a safe and dry location.A MARPOL ANNEX VI bottle label, provided in the sampling kit, should be attached to this sample for correct identification. Details pertaining to the MARPOL Annex VI sample and its subsequent destruction or shipment must be recorded in a sample inventory log.

In case the supplier has taken a representative MARPOL Annex VI sample according to the specified procedures i.e. at the receiving vessel's manifold using a continuous drip sampler and with a label containing the required details, then the supplier's sample is considered the official MARPOL Annex VI sample. In such a case, the DNVPS MARPOL sample should not be used for statutory purposes.

In case the supplier is not in a position to comply with the procedural or documentary requirements stated in Annex VI of MARPOL 73/78, the following actions should be taken by the ship's crew:

A Note of Protest highlighting non-compliance with MARPOL Annex VI requirements should be issued. The Note of Protest is to be forwarded to the relevant Port State.

Reference to the Note of Protest is to be made in the BDN (if supplied).

If the supplier does not provide a MARPOL sample, the ship's crew should propose their own representative MARPOL Annex VI sample to be taken in accordance with the procedures in this instruction manual as the official MARPOL Annex VI sample. The crew should request counter-signing and sealing by the supplier. If this is Accepted by the supplier, a Note of Protest should not be deemed necessary.

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MARPOL Annex VI sample requested by Port or Flag State AuthoritiesThe port or flag state may require the MARPOL Annex VI sample for testing to verify compliance with Reg.14 and 18 of Annex VI, MARPOL 73/78.

In such an event, a receipt should be requested and the action should be recorded in a sample inventory log.

In case the supplier has also provided a MARPOL sample but which is not taken in accordance with the requirements of MARPOL Annex VI, it is recommended that both samples are handed over to the port or flag state authority together with documentation highlighting any discrepancy (Note of Protest).

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Despatching the sample to the DNVPS laboratory

Place the bottle with the Ziplock bag inside the IATA carton box and fold the box as per Assembly Instructions given on the box. Enclose the Chief Engineer's Report form and a copy of the BDN before closing the last flap on the IATA carton. It should be indicated on the C/E form for whom the sample is being tested, since both shipowner and/or charterer could claim credit for the sample if the situation is not clear.

IMPORTANT Chief Engineer's Report Form must be fully completed and sent with the fuel sample. It is also of utmost importance that a copy of the BDN is submitted with the fuel sample.

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Using Correct Colour Label Refer to the DNVPS Air Courier Directory and use the appropriate label for the forwarding box to ensure that the sample is sent to the appropriate DNVPS laboratory.

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If the supplier provides a MARPOL Annex VI sample, but it is found not to have been taken in accordance with the procedures, the suppliers' sample should be countersigned with the appropriate reservations e.g. “For receipt only-source unknown” (using the rubber stamp supplied in the sampling kit). The ship crew should propose their own representative MARPOL Annex VI sample, taken in accordance with the procedures in this instruction manual, as the official MARPOL Annex VI sample. The crew should request counter-signing and sealing by the supplier. If this is accepted by the supplier, a Letter of Protest is not deemed necessary.

If there are technical reasons as to why a sample cannot be taken at the receiving ship's manifold (e.g. vacuum problems and/or extreme weather conditions), then such reasons should be recorded in the ship's log book and the sample taken at e.g. barge manifold.

IMPORTANTThis MARPOL Annex VI sample should be kept onboard in a safe location for minimum 12 months or until the fuel bunkered has been substantially consumed. The sample is only to be handed over to a port or flag state authority.

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Urgent Despatch By Ship's Agent Hand the forwarding box to the ship's agent immediately. Remind your shipping agent to call the courier company to pick up the sample URGENTLY as soon as he gets ashore. Ensure that the agent has all the information necessary to despatch the sample. Stress the urgency of PROMPT despatch. OR Call the air courier directly at the number indicated in the Air Courier Directory, and request URGENT pick up.When the courier arrives, you will need to complete an Airway Bill. Pick up can be arranged a the dock gate or stevedore's office if a courier cannot attend onboard the ship.

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Chief Engineer's Instructions to Ship's Agent Complete the courier despatch instructions on the side of the forwarding box, as indicated in the Air Courier Directory. Fill in the DNVPS Universal Account Number to prevent rejection from DHL. This account number may be found in the Air Courier Directory. Complete the Pro Forma Invoice Form and tape it to the outer side of the forwarding box. The sooner the sample reaches a DNVPS laboratory, the sooner you will receive the test results.

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GENERAL GUIDELINES WHEN BUNKERING

The Bunker Delivery Note (BDN)

It is usual for the supplier or his representative to provide the chief engineer with a BDN. Annex VI of MARPOL 73/78 requires that the BDN contains the following details :0000000000000000000000000000000000000000000000000000000

-Name and IMO number of receiving ship-Bunkering Port-Date of commencement of bunkering-Name, address, and telephone number of marine fuel oil supplier-Product name (grade)-Quantity (metric tons)

o-Density at 15 C (kg/m3))-Sulphur content (% m/m)-A declaration signed and certified by the fuel oil supplier's representative that the fuel oil supplied conforms to regulations 14 and 18 i.e. that the fuel supplied has a sulphur level as specified in the BDN and that the fuel is free from inorganic acid, does not include any added substance or chemical waste which either jeopardises the safety of ships, adversely affects the performance of the machinery, is harmful to personnel, or contributes overall to additional air pollution).00000000000000000000000000000000000000000000000000000000000000000000000000000000000000000

Sometimes these documents are prepared before the delivery and may not reflect the 'facts' of the delivery. We strongly recommend that you do not sign the BDN or any sample labels from the supplier before the bunkering is completed.

Volume deliveriesNormally, the terms and conditions of sale state that the quantity of fuel delivered will be determined by shore meters or measurement of barge outturn.

Please be aware that after the entry into force of the SECAs as defined in Annex VI of MARPOL 73/78, verifying bunkered quantity of low sulphur fuel will become increasingly important. The is because Port State Control Inspectors may scrutinise fuel inventory records in order to verify that the ship has used low sulphur fuel within SECAs i.e. bunkered quantity, recorded consumption within SECA and ROB should balance.

In either case the chief engineer or ship representative should attend to witness opening meter readings or barge soundings and temperature. On completion of the delivery the ship representative should also attend to determine the 'actual' volume delivered. The volume recorded on the BDN should be at standard temperature - calculated by referring to ASTM Petroleum Table 54B.

To convert from volume to weight it is necessary to determine the density of the fuel and, by reference to ASTM Table 56, multiply the volume at standard temperature by the weight factor. DNVPS finds that the density on the BDN is often overstated, resulting in an overstatement of weight delivered.

Receivers of fuel are advised to indicate on the BDN The rubber stamp is provided for your use.

Please ensure that a copy of the BDN is enclosed with your sample in order for us to evaluate the DNVPS density determination against the supplier's statement.

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“For Volume at Observed Temperature Only”.

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General guidelines

A fuel quality dispute can develop at any time, and investigators will need to compile an accurate report if the claim is to be successful. We stress the need for good routine record-keeping onboard the vessel as 'after the fact' accounting is difficult and confusing. The DNVPS system will provide support in such cases but the chief engineer, by following the guidelines listed here, will improve the chances of success :00000000000000000000000000000000000000000000000000

1. Keep a daily record of fuel quantities held onboard in each tank. Record transfers of fuel by date and amount transferred from tank to tank.

2. Keep careful records of oil bunker deliveries, recording quantity in all tanks before and after delivery.

3. Whenever possible, do not mix fuel from different deliveries and always load into empty tanks.

4. Keep analysis records of all samples.

5. Retain suppliers' samples and samples taken by ship staff for a minimum period of six months. Ensure that they are correctly labelled, sealed and stored in a safe location.

6. Retain the MARPOL Annex VI sample for a minimum of 12 months or until the fuel has been substantially consumed. Ensure that the sample is correctly labelled as per MARPOL Annex VI requirements, sealed and stored in a safe location.

7. Ensure that BDNs are in accordance with MARPOL Annex VI requirements . Keep copies of all BDNs readily available onboard for a minimum of 3 years.

8. Keep good records on main engine and auxiliary inspections and repairs.

9. Ensure that engine room or machinery log books record temperatures and pressures, so that abnormal conditions can be recognised and related to a particular period.

10. In case of damages, compile a statement or record of events which should include date, times, damages and costs (including manhours and spare parts). Also retain broken or damaged parts for future inspection. Photographs of damages may also prove useful.

11. If problems are encountered, samples of the fuel in use should be are drawn from the fuel system as detailed below.

Disputes arising from poor quality fuel deliveries can be complex and what may seem to be a simple case can become very convoluted with respect to documentation, samples and alleged damages.00000000000000000000000000000000000000

Fuel tank and system sampling:

From time to time, it will be necessary to draw fuel samples from the ship's tanks or fuel system. This may be required to confirm a poor fuel quality delivery, to resolve a fuel handling problem, or check the performance of fuel treatment plant components. Again, we must stress that analysis of such samples can only be useful if they have been taken properly.

The following notes are intended as guidelines under such circumstances.

Tank samplingIdeally, to evaluate the quality of fuel stored in a tank, the following samples should be obtained :

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INVESTIGATIONS AND SAMPLING OF TANKS AND FUEL SYSTEMS

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The above samples should not be mixed together but submitted for analysis as individual samples. The label on each bottle must record the date, the sample type and tank location.

Sampling devices designed for such sampling should be used. If sampling equipment is available on board, ensure that it is thoroughly cleaned before use. In some cases, due to limited access to tanks, it is not possible to obtain tank samples as described above. Under these circumstances, a sample may be taken at the fuel transfer pump as described below.

Transfer pump samplesIf practical, line up the fuel oil transfer pump to discharge the tank to be sampled to an empty fuel oil tank. On the discharge side of the transfer pump, select a suitable position for taking a continuous-drip sample.

If the suction or discharge lines of the pump contain oil from previous transfers, start the pump and run it for a sufficient period to empty the lines. After this, start sampling by taking a continuous-drip or stream of oil into a clean cubtainer. Continue to collect the sample until the tank is empty, during which time you should have adjusted the sample flow to collect some five litres of oil. If an empty tank is not available, take a continuous-drip sample from the transfer pump discharge during circulation of the oil back to the same tank.

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Thoroughly mix the 5-litre sample and pour one litre into a DNVPS bottle.

Mark the sample as 'Continuous-drip - Fuel tank contents during discharge' together with the tank number.

DO NOT

a. take the sample from tank bottom drain valves. These will probably contain high levels of water and sediment which will not be representative.

b. take sample from sounding pipes - again these will not be representative.

Fuel treatment system samplesEven if a delivered fuel meets the ordered specifications, it is imperative that the fuel treatment plant is operating at maximum efficiency or engine damage may occur.

Sampling from a fuel system when a problematic fuel is loaded will also help indicate the efficiency of the treatment plant and thus assist the crew in taking preventive action, if needed.

Sampling before and after separators is also considered the only feasible condition and performance monitoring of the fuel.

Periodic sampling from the fuel treatment system will also identify such problems as water ingress from ballast systems, leaking heating coils and cargo contamination. A good fuel management system would include such sampling and analysis at least once a year.

The DNVPS Fuel System Check (FSC) can assist your ship in this regard. Further information and detailed instructions for fuel system check sampling is provided in this manual.

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a) Top sample - taken at approximately 6 inches below the surface of the oil.b) Upper sample - taken from the middle of the upper one-third of the tank's contents.c) Middle sample - taken from the middle of the tank's contents.d) Lower sample - taken from the middle of the lower one-third of the tank's contents.e) Bottom sample - taken from the bottom surface of the tank.

Sludge samplesSludge samples taken from tanks, purifiers and pipelines can provide useful information, but without fuel samples taken at the same time, the analysis results cannot be put into context. Thus, it is important to submit both sludge and fuel samples. It must be accepted that sludge samples may contain high amounts of water and sediment accumulated over a period of time from several bunker deliveries.

Combustion deposit samplesInvestigations into fouling of combustion spaces, exhaust system and turbo charges by ash and unburnt fuel can be advanced by analysis of deposit samples. Again, samples of fuel used prior to the fouling should also be submitted to assist with the problem-solving process.

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FUEL SYSTEM CHECK (FSC)

Why Fuel System Check?

The purpose of the DNV Petroleum Services (DNVPS) Fuel System Check is to utilise sample analysis for monitoring the condition of the fuel system and the effectiveness of fuel treatment. Essentially, the ship staff draws samples periodically or in case of operational problems or as triggered by our Fuel Analysis reports in connection with poor quality bunker deliveries. The samples are then analysed and the results assessed by DNVPS.

With the instructions provided herein, you will have all the information needed to take full advantage of this programme.

Fuel standards such as ISO 8217 specify quality at the ship's manifold. It is presumed that quality will not deteriorate in storage on board and that there will be adequate treatment before use.

Experience gained by DNVPS and its customers since the introduction of the DNV Fuel Quality Testing programme, coupled with studies and research, confirms that fuel treatment systems are not always operated at optimum efficiency. Fuel contamination may also occur in the vessel's fuel system and tanks due to defective steam heating coils or seawater/cargo ingress resulting from badly located or damaged vent pipes.

Efficient and proper centrifuge operation is also essential for the removal of contaminants in the bunkers. With the Fuel System Check program, malfunction and defects in the centrifuges can be identified; while post-separator sampling helps uncover possible filtering problems such as filter mesh rupture.

For example, ISO 8217, the most commonly referred to marine fuel specification in the market, indicates 80 mg/kg Aluminium + Silicon (Al+Si) as the maximum amount of catalyst particles permitted in the fuel as delivered. However, major marine engine manufacturers recommend not more than 15 mg/kg Al+Si at the engine inlet. Hence, assuming a delivered fuel contains 75mg/kg Al+Si, your purification system has to operate at an efficiency level capable of removing 80 per cent of these highly abrasive materials, in order to meet the engine manufacturers' requirement.

The purpose of Fuel System Check is to monitor the shipboard fuel system, i.e. the 'gap' between the ship's manifold and the engine, in a systematic manner. This is done by analysing samples drawn from key locations to assess the total fuel system.

Sampling and DistributionFor analysis results to be useful, sampling must be carefully carried out at key locations that can provide a picture of fuel quality variation throughout the fuel system. Samples for Fuel System Check can be taken at fixed intervals, say, once or twice annually, or in connection with poor quality bunker deliveries or operational problems.

Figure 1 (Sampling Positions & Sample Identification Letters) shows the locations from which Fuel System Check samples are to be drawn.

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A standard set of Fuel System Check samples consists of one sample taken from each of the following locations (see Figure 1):

A. The Transfer Pump dischargeB. The Separator inlet (Note: samples should not be taken from tank drains as our experience shows that these samples

are in general not representative of the fuel in use)C. One from the outlet side of the HFO separators or day/service tank

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Note - Additional samples can be drawn after the individual fuel cleaning components. For a detailed breakdown of Sampling Positions and Codes, please refer to Figure 2.

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For ease of sampling, we strongly recommend that these connections be fitted with sampling cocks or valves. A connecting pipe may extend to a convenient position for sample collection. Ideally, a facility might be provided to allow for the flushing of the connection back to the system or to a waste tank. The sample should not be drawn from Tank Drains as DNVPS' experience shows that such a sample is in general not representative of the fuel.

Sampling ProcedureFor the assessment of the analysis results to be as meaningful as possible, the samples must be drawn at around the same time. Routine and requested sample sets should be taken when the fuel from the last bunkering has worked well through the system, even if two or more bunkerings have had to be mixed together.

All sampling equipment should be clean and in good order. Oil, sludge, water, cleaning solvents etc, from previous samplings can cause erroneous analysis results.

Bearing in mind the hazards of hot oil under pressure, samples should not be taken from the high pressure booster part of the fuel system.

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Sampling and Labelling

Fill the sample bottle. Make sure each bottle is clearly marked to prevent mix-up.

Attach the red Fuel System Check label on the sample bottle.

Pack the FSC samples in the FSC transportation box

Attach the address labels according to instructions in the ACD.

Fasten the bottle cap securely to prevent leakage.

1. The sample bottles from the FQT sampling kit can be used.

2. Mark each sample container clearly before sampling to prevent mix-up.

3. Ensure the lines are flushed through before drawing the sample.

4. The sample may be filled directly into the plastic sample bottles.

5. The plastic bottle cap should be firmly fastened after sample has cooled to avoid leakage.

6. Ensure each sample is clearly labelled with the Fuel System Check sticker.

7. Complete the sample record form as provided in this manual. The original should be sent with the samples, together with other relevant documentation. The copy is for the ship's file.

8. Pack the three Fuel System Check samples in the FSC cardboard transportation box. Attach the laboratory address labels according To instructions given in the FQT Air Courier Directory (ACD).

RED

The recommended procedure is as follows:

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Safety The usual safety precautions should be followed and the guidelines provided below should be read in conjunction with the appropriate standards and codes of practice.

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1. Regulations regarding the entry into hazardous areas should be strictly observed.2. Smoking and naked lights should be prohibited in the vicinity of oil vapours.3. Sampling equipment and lights should not pose an electrical risk.4. When handling fuels, or cleaning fuel treatment components, ensure oil-resistant gloves are worn and eyes are protected.

Forwarding the samples

The Fuel System Check samples should be sent to the nearest DNVPS laboratory for analysis. The address labels are provided in this manual.

Please instruct your agent to fill out the required customs declarations and contact the nearest courier service listed in our Air Courier Directory.

By agreement with DNVPS, the sample boxes will be forwarded by our international network of courier agencies. The ship agent should be instructed to request pick-up and dispatch according to Chapter 2 of our FQT Instruction Manual. Standard pro forma invoices, as enclosed in this manual should be filled out and attached to the sample box.

Testing & Reporting the Samples

Samples submitted for analysis under the Fuel System Check programme will be analysed for a number of key parameters in order to identify the fuel and assess the onboard fuel treatment plant.

The test parameters Density and Vanadium are used to “fingerprint” the fuel in order to confirm that the fuel samples correspond with the bunkered fuel.

In order to assess the onboard treatment, the following parameters will be measured:

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Water - Used to monitor if any settling of water has taken place and/or if there is any water contamination; for example, from steam heating coils or leaking solenoid valves on the separators.Sodium - High Sodium can cause increased corrosion of the high pressure parts of the fuel system and to exhaust valves as well as increased deposits in the post-combustion spaces.Aluminium + Silicon - These abrasive particles, otherwise known as “cat fines” can cause significant damage to an engine. Areas such as fuel pumps and injectors and the liners and piston rings can be subject to high wear rates if the “cat fines” content is not reduced down to a satisfactory level as recommended by your engine manufacturer(s).Iron - If present, this would most likely be in the form of Iron Oxide (Rust) and as such would be removed by the separator(s).

Total Sediment Potential (TSP) - This parameter is used to assess and indicate the Stability and Cleanliness of a fuel. Fuels with high Sediment content can cause increased sludge problems in the separators.

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The analysis report for the Fuel System Check samples will be sent to designated recipients in the same manner as the test results from the fuel analysis samples.0000000000000000000000000000000000000000000000000000000000000000000

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GUIDELINES ON INTERPRETING TEST PARAMETERS

Densityo3Density is expressed in kilograms per cubic metre (kg/m ) at 15 C. Density mainly affects the fuel separation.

Conventional separators can remove water and to some extent solid particles from heavy fuel oils with densities up to o o3 3991kg/m @15 C. Separators of newer design can clean heavy fuel oils with densities up to 1010kg/m @15 C. An

important issue is to ensure that the correct separation flow rate and temperature are used in order to achieve an efficient reduction of water, catalytic fines, sodium and sediments from the heavy fuel. Further, the exact density must be known to verify the weight of the fuel based on the received volume.

Viscosity2Viscosity is expressed in mm /s (centistokes, or cSt) at a stated temperature. This is a measure of a fluid's resistance to

flow. The kinematic viscosity is measured by the time for a fixed volume of oil to flow through a capillary tube.

Viscosity is not actually a measurement of heavy fuel oil quality. The user of the fuel will need to be aware of the viscosity in order to set heaters correctly, prior to pumping and cleaning or treating the fuel, and before injection into the main engine. This is because heavy fuel oil must be heated to reach the correct injection viscosity to ensure optimized combustion and engine performance.

If the viscosity of the fuel is too high, the heating plant may not be capable of raising the fuel to the correct temperature. In extreme cases, transfer of the fuel onboard may be very difficult and the engine could suffer poor performance and possibly damages if insufficient heating is applied prior to injection.0000000000000000000000000000000000000000000

Heavy fuel oils are also generally priced and ordered according to viscosity.

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WaterWater content is expressed as per cent by volume. Water reduces the specific energy of fuel oil, thereby increasing consumption and reducing fuel economy. Water may cause corrosion in the fuel system. The sodium chloride (salt) in sea-water can also promote corrosion by giving rise to the formation of sodium-vanadium compounds during combustion (high temperature corrosion). The water content in heavy fuel oils is low during production; thus the presence of water in bunker oil is usually due to external contamination.

Separation of water from fuel oil can be a slow process, particularly if the difference in density is small or if the water is present as minute drops. Separation of water drops is also inhibited by various small-particle impurities, such as dust, sand and rust. The resulting emulsion clogs filters and affects efficient centrifuging.

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Sulphur

Carbon Residue

The carbon residue level indicates the coke-forming tendencies of a fuel and is expressed as per cent by weight. Fuel oil with a high carbon residue may cause combustion deposits, particularly when the engines are running at low load.

The sulphur level in fuel contributes to sulphur oxide emissions and thus air pollution. Annex VI of MARPOL 73/78 includes a worldwide 4.5% maximum sulphur content in fuel. In the Sulphur Emission Control Areas (SECAs), the maximum sulphur content is 1.5%.

Sulphur compounds may corrode cylinder liners and piston rings. The sulphur dioxide generated by combustion may cause corrosion in exhaust passages at low temperatures.

Engines designed for operation on high sulphur fuels use special lubricants and operate at higher temperatures to minimise the effects of sulphur. The sulphur content of a fuel affects the energy available.

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Sediment

All fuels contain sediment consisting of hydrocarbon sludges and extraneous materials. The Total Sediment Test is designed to determine the quantity of non-fluid material in the fuel by a hot filtration method.000000000000000000000

AshAsh represents the incombustible components of fuel oil. These components may have their origin in the fuel or may have been introduced by poor house keeping. High ash levels can cause wear in the fuel injection system, deposits on cylinder components and resultant wear. In addition, some ashes are corrosive and may stick on to exhaust valves. High ash levels may also reduce the efficiency and cause damage to turbochargers.

Small particles of the catalyst (aluminium and silica oxides) used in the refinery process are sometimes carried over into the residual fuel. They range in size from about 5 microns to 120 microns and are of irregular shape, porous and extremely hard. Some degree of removal may be achieved by settling and centrifuging onboard ship. Due totheir abrasive nature, they can lead to rapid wear of fuel injection system components and cylinder rings/liners.

ISO 8217 prescribes a maximum level of 80 mg/kg aluminium + silicon in fuels as delivered to vessels. However, fuel deliveries with levels of aluminium and silicon far in excess of this value have been recorded and severe engine damages have been attributed to such high catalytic fine levels. Note that a single separator is not capable of handling aluminium + silicon levels above 50mg/kg in order to reduce the aluminium + silicon contents to an acceptable level at main engine inlet. We therefore recommend operating two or more separators in parallel or series, depending on type, when the tested level is in the 50-80 mg/kg range.

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Catalytic Fines

ElementsFuel oils contain many metals, of which the most common are vanadium, nickel, iron and sodium. Vanadium and sodium are perhaps the most dangerous as they may lead to high temperature corrosion. The worst situation is whenthe ratio of vanadium to sodium is approximately 3:1. Sodium salts are water-soluble and can be removed with water during treatment. Vanadium, however, is oil soluble and cannot be removed by onboard fuel treatment equipment.

Flash PointThe flash point is expressed in degrees centrigrade. Safe transport and storage requires that the flash point of the

ofuel oil is known. A flash point minimum of 60 C is prescribed for use onboard ships in the machinery spaces. This minimum temperature is stated in the rules of classification societies and legislated by most governments.

CCAI Ignition QualityA rough indicator of ignition quality, Calculated Carbon Aromaticity Index (CCAI) as developed by SHELL is calculated on the basis of an empirical formula that includes density and viscosity. The CCAI is a useful indication of the ignition quality of the fuel, but has in some cases proved not to be sufficient for prediction of the ignition quality. To determine fuel ignition properties more accurately, DNVPS is offering a laboratory test using a Fuel Ignition Analyser (FIA). Please refer to the chapter on Extended Analysis for more information.000000000000000000000000000000000000000000000

FT-IR scanning of MDO samples

FT-IR scanning is performed on all distillate fuel samples received by DNVPS laboratories. FT-IR scanning enables detection of added substances such as esters and other oxygenated compounds in diesel and gas oils. It also indicates elevated amounts of organic acid found in the fuel. If the FT-IR scanning shows unusual amounts of organic acids, the Acid Number Test will be performed.

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MARPOL Annex VI Services

Sulphur content testing:

DNVPS strongly recommends that ships participate in a fuel quality testing programme as this is considered to be a highly cost- effective risk management tool in terms of safeguarding the ship's engines from the adverse effects of poor fuel oil quality.

Based on clients' requests, DNVPS has further developed a service where owners can submit fuel oil samples for verification of compliance with the sulphur content requirements of Annex VI to MARPOL 73/78. The service is available for marine fuel oils, diesel oils and gas oils.

Fuel sulphur content verification is recommended for the following reasons:

- Low sulphur fuel is anticipated to come at a premium compared to normal sulphur fuel, i.e. there is a commercial interest in verifying that the fuel quality is in accordance with the specification. - It is considered preferable to verify the actual sulphur content in advance as opposed to testing on the order of the port state control. Verification in advance represents an opportunity to be pro-active, i.e. notify flag states and port states on any failure on the part of the supplier in delivering MARPOL Annex VI compliant fuels. - Prior verification could limit potential problems in case the vessel is using lubrication oils with a TBN adapted to low sulphur fuel oils only. - It serves as a means to limit the emission of sulphur oxides within SECAs, i.e. fulfil the ship's obligation towards safeguarding the environment.

Besides sulphur, the scope of testing also includes density in order for owners to verify that the actual density is in accordance with that specified in the supplier's BDN. This is considered increasingly important as one can anticipate that bunkered quantity together with recorded consumption and ROB will be scrutinized so as to determine that only low sulphur fuel has been consumed within SECAs.

The MARPOL Annex VI low sulphur service is however identical to the complete DNV Fuel Quality Testing programme in terms of the sampling kits, sampling procedures and sample shipment instructions contained in this instruction manual.

Subscription to the low sulphur service therefore ensures the availability of MARPOL Annex VI compliant sampling kits (bottles, labels, instructions etc) as well as access to DNVPS' bunker alerts, fuel quality statistics, line samplers and other DNVPS services.

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Verification of fuel change-over procedures:

Regulation 14 of MARPOL Annex VI requires a ship has to have completed the change-over from normal to low sulphur fuel prior to crossing the SECA border. Completion of change-over means that the fuel consumed in any boiler or engine onboard (regardless of service or output) upon crossing the defined SECA border must have a sulphur content of 1.5% or below.

The time required for this change-over will deviate depending on the tank and piping system configuration onboard. Although change-over from one fuel quality to another is nothing new onboard ships, MARPOL Annex VI has specific requirements for the completion of such change-over. It is therefore recommended that additional focus should be put on the development of proper procedures as MARPOL Annex VI is a statutory requirement subject to statutory surveys and controls.

In order to verify whether the change-over procedures developed comply with the requirements of MARPOL Annex VI, DNVPS has developed a service where owners can take in-system samples before and upon completion of change-over and submit them to DNVPS for testing.

Such verification can be carried out without low sulphur fuel being onboard, as long as fuel oils of different grades are used.

DNVPS will test submitted samples for density, viscosity and sulphur in order to determine whether complete change-over between fuel grades has been achieved. The results of the tests will enable owners to adjust the change-over procedures to ensure future compliance.

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Sampling points:The sampling points depend on the fuel tank and piping system configuration onboard. The following sampling points are however recommended:

1. Outlet from fuel oil settling tank(s): -In order to confirm that complete replacement of fuel oil in settling tank has been achieved. 2. Outlet from fuel oil service tank(s): -In order to confirm that complete replacement of fuel oil in service tank has been achieved.3. Fuel supply piping immediately before each engine and boiler burner arrangement: -In order to confirm that complete change-over of fuel oil supplied to engines and boilers has been achieved. -Aternatively one could consider taking similar samples in return oil piping from engines and boiler burner arrangement.

In order to limit the number of samples taken, one could limit the scope to the service tank outlet or from the common supply piping to main engine(s), auxiliary engines and boiler(s). However one needs to bear in mind that this will not necessarily reflect the quality of the fuel being consumed in the respective engine/boiler. Please ensure that at the time of sampling safety precautions are taken due to potential hazards if sampling is carried out from the pressurised fuel oil booster system(s).

Sampling equipment:For ease of sampling, we strongly recommend that the sampling points are provided with sampling cocks or valves. A connecting pipe may extend to a convenient position for sample collection. Ideally, a facility might be provided to allow for the flushing of the connection back to the system or to a waste tank.

All sampling equipment should be clean and in good order. Oil, sludge, water, cleaning solvents etc, from previous samplings can cause erroneous analysis results.

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Sampling Procedures:One sample should be taken at each specified sampling point:­ Before commencement of change-over.- Immediately upon completion of change-over, which is considered the official time to be recorded in the ship's

logs as per MARPOL Annex VI requirements

Sampling and Labelling

Fill the sample bottle. Make sure each bottle is clearly marked to prevent mix-up.

Fasten the bottle cap securely to prevent leakage

Attach the red Fuel System Check label on the sample bottle.

The recommended procedure is as follows:

1. The sample bottles from the FQT sampling kit can be used. Ensure that a sufficient number of bottles, cardboard boxes and labels are available.

2. Ensure that each sample bottle is provided with a red FSC label and mark each label clearly before sampling to prevent mix-up as follows:“FUEL CHANGE-OVER”-Whether sample is taken before or upon completion of change over. -Sampling point location.

3. Ensure the lines are flushed through before drawing the sample.

4. The sample may be filled directly into the plastic sample bottles. 300 to 400 ml is all that is required for the program. As such, the bottles only need to be half filled.

5. The plastic bottle cap should be firmly fastened after sample has cooled to avoid leakage.

6. Complete the FSC sample record form as provided in this manual. The original should be sent with the samples, together with other relevant documentation. The copy is for the ship's file.

7. Pack the samples in the Fuel System Check carton box. Attach the laboratory address labels according to our Air Courier Directory.

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Forwarding the samplesThe samples should be sent to the appropriate DNVPS laboratory for analysis. The address labels are provided in this manual.

Please instruct your agent to fill out the required customs declarations and contact the nearest courier service listed in our Air Courier Directory.

By agreement with DNVPS, the sample boxes will be forwarded by our international network of courier agencies. The ship agent should be instructed to request pick-up and dispatch according to Chapter 2 of our Instruction Manual. Standard Pro Forma invoices, as enclosed in this manual, should be filled out and attached to the sample box.

Verification frequency:The above comprehensive sampling is considered necessary in connection with development of change-over procedures. It is however recommended that periodic verification of procedures are carried out, but with a reduced scope incorporating sampling from settling and service tank(s) outlets only.

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Onboard blending - Blend Optimisation Programme (BOP):

Due to uncertainty with respect to availability of low sulphur fuel oil, certain owners have indicated that they intend to blend fuel onboard to meet the low sulphur requirements.

The following issues need be considered in connection with onboard blending:

- Are the different grades of fuel oils and distillates (diesel and gas oil) compatible ?

- What is the minimum amount of the more expensive low sulphur fuel oil, marine diesel oil or gas oil that can be used, while ensuring that the sulphur specification and engine specification is met ?

- What is the resulting viscosity of the optimum blend ?

- What is the correct injection temperature of the blended fuel ?

- How can the ship verify and document the resultant sulphur content in the blend to a third party.

To limit the above uncertainties, DNVPS offers its Blend Optimisation Programme (BOP). This programme will enable owners engaging in onboard blending to optimise the composition of blended marine fuels to ensure that the most economic blends are used; that the blends meet the engine manufacturers' requirements to fuel oil quality; and that the risk of blend incompatibility, which can lead to severe sludging and potential operating problems, is reduced.

The Blend Optimisation Programme will consider the critical specifications of the blend components and the non-linear viscosity blending characteristics. The programme will provide the technical expertise and experience to determine optimum blend composition and will also verify whether the blend components are compatible.

By submitting a representative sample of each blend component, the Blend Optimisation Programme will undertake the following:

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- Fuel quality testing of the blend components - Compatibility check of the blend components- Calculation of the resultant blend viscosity- Recommendations on optimum blend composition to meet engine fuel specifications and correct injection temperature - Technical advice on the overall fuel quality

Bunkering Operation ID No : Hints

Indicate quantity received in Metric Tons. Low sulphur fuel consumption within SECA's becomes a statutory requirement and may therefore be subject to third party verification/control. Accordingly, it is reccommended that increased focus is put on bunker quantity measurements and testing of density to acertain that the quantity received is in accordance with BDN value.

Bunker barge(s)/Terminal(s) Name

BDN in compliance with MARPOL Annex VI

Date of bunkering Indicate date bunkering was performed (start and completion).

Bunker Grade(s)Indicate Product's name/Grade as per Bunker Delivery Note or specification. ISO grades preferably to be used.

Quantity (MT)

Port of Bunkering Indicate the Port where the bunkering operation was performed

Name of Supplier Indicate Name of supplier

Indicate Name of bunker barge(s) or bunker terminal(s).

Supplier Registration with Port State Authorities

Answer with Yes, No or Unknown with respect to whether the Supplier is Registered with Port State Authorities or not. Note that MARPOL Annex VI does require Port States to maintain such a register. Although not a requirement, it is reccommended that only registered suppliers are used.

Answer with Yes, No. It is a requirement that for every barge and grade delivered to the ship is accompanied by a Bunker Delivery Note (BDN). The BDN is to contain Name and IMO no. of receiving ship, Port, Bunkering date, Suppliers Name/Adress/Telephone no., Product name,

oQuantity (MT), Density at 15 C (kg/m3), Sulphur content (% m/m), A declaration signed by the supplier's rep. stating that the fuel is in conformity with Reg.14(1) or 4(a) and Reg.18(1) of Annex VI to MARPOL. If the BDN does not contain the required information and declaration, a Note of Protest should be issued. The BDN is to be retained onboard for min. 3 years.

MARPOL sample received from supplier

Answer with Yes or No. Note that every BDN is to be accompanied by a MARPOL sample representative for the fuel supplied. The sample is to retained onboard for min. 12 months. The sample is to be min. 400 ml and provided with a lable with information regarding; Location where sample was taken (ship manifold), Sampling method, Bunker date, Name of bunker barge/pier, Receiving ship name and IMO no., Sample seal number and Bunker grade. Every sample is to be sealed by supplier and label is to be signed by the Officer in charge of the bunkering and the suppliers' rep. It is the suppliers responsibility to provide such a a sample. See however below requirements. If the supplier does not provide a MARPOL sample, a Note of Protest should be issued and the separate MARPOL sample taken by the ship's crew in accordance with the DNVPS instruction manual should be maintained onboard together with the supplier's sample.

Supplier’s MARPOL sample taken at ship’s manifold

Answer with Yes or No. The guideline to Annex VI (MEPC. 96(47)) specifies that the MARPOL sample is to be continously drawn at the receiving ship's manifold. In case the supplier does not take the MARPOL sample at the ships' manifold, a Note of Protest should be issued and the separate MARPOL sample taken by the ship's crew in accordance with the DNVPS instruction manual should be maintained onboard together with the supplier's sample. If there are operational constraints such as vacuum problems that prohibits samples to be taken at the ship's manifold, this should be recorded separately and the sample taken e.g. at barge manifold.

Note of Protest issued Answer with Yes or No. The Note of Protest should be referred to in the BDN.

MARPOL sample seal nos. MARPOL Sample bottle seal number(s) are to be specified. Note that it is reccommended that all seal number(s) related to bunker samples tanken are recorded in the BDN (Requirement in Singapore)

Other sample sent for fuel quality testing

Answer with Yes or No. Applicable if the vessel sends other fuel samples for fuel quality testing. The MARPOL sample is to be retained onboard and not be used for commercial disputes. I.e. the sample is only be handed over to a Port or Flag state Authority upon request.

Sulphur content (%m/m) Indicate the sulphur content as indicated on the Bunker delivery note (BDN)

Stored in Tank No. And quantity

Indicate in which tank(s) the received fuel was stored with specified quantity in each tank.

Date when fuel was substantially consumed

Indicate the date that the quantity of the fuel bunkered was substantially consumed.

Sample disposal date The disposal date should be indicated. All samples should be stored onboard for a minimum of 12 months or until the fuel was substantially consumed - whichever is greater.

Sample given to Authorities

The date on which the sample was given to an Authority for verification should be indicated with port and name of authority, if applicable. A receipt should always be obtained. In case the supplier's sample is not taken as per Annex VI requirements, both the supplier's sample, the DNVPS MARPOL sample and a copy of the Note of Protest should be handed over.

MARPOL ANNEX VI SAMPLE RECORD - GUIDELINES (Proposed By DNVPS)

Answer with Yes or No. The guideline to Annex VI (MEPC. 96(47)) specifies that the representative MARPOL sample is to be continously drawn throughout the bunkring period and is to be obtained either by a manual valve-setting continuous drip sample or an automatic sampler. The sampling equipment and the attached receving container is to be sealed throughout the bunker delivery period. If the suppliers' sample is not taken using a cont.drip or auto-sampler, a Note of Protest should be issued and the separate MARPOL sample taken by the ship's crew in accordance with the DNVPSinstruction manual should be maintained onboard together with the supplier's sample.

MARPOL sample taken with continuous drip sampler

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DNVPS GUIDELINES FOR ISSUING NOTE OF PROTEST REGARDING MARPOL ANNEX VI

The vessel's Master may be required to issue Note of Protest to bunker supplier if the bunker supplier fails to comply with the MARPOL ANNEX VI requirements.

The vessel's Master should note the following possible non-compliance situations and choose the relevant item/s to be quoted in the Note of Protest:

000000000000000000000000000000000

A Bunker Delivery Note was not provided for every delivery/grade.

The Bunker Delivery Note did not contain the required information. (In this section further elaboration is needed to state which information was not given. Refer further explanation under Regulation 18(3) App.V).

A MARPOL Annex VI sample did not accompany each Bunker Delivery Note.

The MARPOL Annex VI sample(s) was not taken at receiving ships manifold.

The MARPOL Annex VI sample(s) was not taken by continuous drip sampler or auto-sampler.

The MARPOL Annex VI sample(s) was not provided with seal and a label containing the required information. (In this section further elaboration is needed to state which information was not given. Refer further explanation under Regulation MEPC.96(47) Item 8).

Other (please specify):

1

2

3

4

5

6

7

For convenience, an Example of a Note of Protest is shown is shown later in this document.

Further explanation of the possible non-compliance items related to Regulation 18 of Annex VI to MARPOL 73/78 is as follows:

­ Name and IMO No. of receiving ship. ­ Port ­ Date of commencement of delivery. ­ Name, address and telephone no. of marine fuel oil supplier ­ Product name ­ Quantity (metric tons)

o 3 ­ Density at 15 C (kg/m ) - as per ISO 3675. ­ Sulphur content (% m/m) as per ISO 8754. ­ Declaration signed and certified by the suppliers rep. that the fuel supplied is in conformity with Reg.14 (1)* or 4(a)** and Reg.18(1)*** of Annex VI to MARPOL 73/78.

* The sulphur level in the fuel supplied is less than 4.5%. ** The sulphur level in the fuel supplied is less than 1.5%. *** The fuel is free of inorganic acids and does not include any added substance or Chemical waste which either 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.

18(3)

18(3) App.V

Regulation Description

A Bunker Delivery Note was not provided for every delivery and grade supplied.

The Bunker Delivery Note did not contain the required information as follows:

A MARPOL Annex VI sample did not accompany each Bunker Delivery Note.

The MARPOL Annex VI sample(s) was not taken at the receiving ships manifold.

The MARPOL Annex VI sample(s) was not taken by a continuous collection of drip sample throughout the delivery of fuel (i.e. by continuous drip sampler or auto-sampler).

The MARPOL Annex VI sample(s) was not provided with a label containing the required information as follows: ­ Location at which, and the method by which, the sample was drawn ­ date of commencement of delivery; ­ name of bunker tanker/bunker installation; ­ name and IMO number of the receiving ship; ­ signatures and names of the supplier's representative and the ship's representative; ­ details of (tamper proof) seal identification; and ­ fuel grade.

18(6)

MEPC.96(47) Item 6

MEPC.96(47) Items 4 & 6

MEPC.96(47) Item 8

Note that MEPC.96(47) is the “Guidelines for the sampling of fuel oil for determination of compliance with Annex VI of MARPOL 73/78”, which is referred to in Reg.18(6) and which IMO has invited Governments to apply from the date of entry into force of Annex VI to MARPOL 73/78.

EXAMPLE -- MARPOL ANNEX VI NOTE OF PROTEST

Date :____________________________________

To : ____________________________________ (Name of Supplier)

____________________________________ (Address and telephone number)

Dear Sirs,

NOTE OF PROTEST FOR BUNKERING OPERATION ON ___________________________(Date)

This is to record that the stated Supplier failed to comply with the MARPOL Annex VI requirement as follows:

The bunkers were supplied by Bunker Tanker/Barge ______________________________________

(Name of Bunker Tanker/Barge) on _____________(Date) at ______________________(Location).

I hereby lodge a protest to reserve rights for any future consequences on this matter.

Yours faithfully,

_________________________ _____________________________________________ (Name of Master of Vessel) (Signature of Master of Vessel and Vessel Stamp)

ACKNOWLEDGEMENT RECEIPT

__________________________________________________Name of Master/Cargo Officer of Bunker Tanker/Barge)

______________________________________________________ _____________________(Signature of Master/Cargo Officer of Bunker Tanker/Barge) (Date)

DNVPS/FQTK_IM/V1R0/0405

DNVPS Regional Office & LaboratoryHouston, Texas, USA 318 North 16th StreetLa Porte, Texas 77571, USATel: + 1 281 470 1030 Fax: + 1 281 470 1035Email: houston@dnvps.com

DNVPS Regional Office & Laboratory Rotterdam, The Netherlands Haastrechtstraat 7 3079 DC Rotterdam P.O. Box 9599 3007 AN Rotterdam The NetherlandsTel: + 31 10 292 2600 Fax: + 31 10 479 7141Email: rotterdam@dnvps.com

DNVPS Regional Office London, UK Palace House 3, Cathedral Street London SE1 9DE United KingdomTel: + 44 0207 357 6080 Fax: +44 0207 716 6736Email: london@dnvps.com

DNVPS Worldwide HQ Regional Office & Laboratory Singapore 27 Changi South Street 1 Singapore 486071Tel: + 65 6779 2475 Fax: + 65 6779 5636Email: singapore@dnvps.com

DNVPS Regional Office & LaboratoryOslo, Norway Veritasveien 1 N-1322 Hovik, NorwayTel: + 47 67 57 9900 Fax: + 47 67 57 9393Email: dnvps.oslo@dnv.com

DNVPS Regional Office & LaboratoryFujairah, UAE Port of Fujairah P O Box 1227 United Arab EmiratesTel: + 971 9 2228152 Fax: + 971 9 2228153Email: fujairah@dnvps.com

DNV is a global provider of services for managing risk. Established in 1864, DNV is an independent foundation with the objective of safeguarding life, property and the environment. DNV comprises 300 offices in 100 countries, with 6,400 employees.