As the Chief Engineer of a motor vessel equipped with engines capable of burning both high sulfur content residual fuels and low sulfur content distillate fuels, on approaching arrival to a US port, for planning purposes, what must be done?
• SOx Emissions Control Area (ECA) fuel requirements under MARPOL Annex VI and U.S. implementation in 33 CFR/46 CFR • Difference between residual (high sulfur) fuel and distillate (low sulfur) fuel in the fuel system piping and service tanks • The need to plan enough time for flushing high sulfur fuel from lines, pumps, and engines before operating in the ECA
• When you cross into a SOx ECA, at that exact moment, what fuel must actually be reaching the engine injectors? • Does the changeover process happen instantly at the ECA boundary, or does the system need time for the new compliant fuel to push the old fuel through the lines and equipment? • From a compliance and recordkeeping standpoint, do regulations expect you to be "just in time" at the line, or to have a margin of safety before entering the ECA?
• Verify that compliant low sulfur fuel must be in use (not just in the tank) when operating inside the ECA boundary. • Consider how long it typically takes for a full fuel changeover and fuel system flushing on a large main engine burning residual fuel. • Think about what the easiest option to prove compliance in the logbook would be: starting changeover before, at, or after the ECA boundary.
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