IMO Marine Environment Protection Committee (MEPC), has clarified how energy-rich fuels or their blends with petroleum oils subject to Annex I of MARPOL and/or with biofuels subject to Annex II of MARPOL can be shipped in bulk under the correct annex of MARPOL, by providing the Guidelines for the carriage of energy-rich fuels and their blends.
DESCRIPTION OF ENERGY-RICH FUELS
An energy-rich fuel is obtained from biological origin or non-petroleum sources (e.g. algae, vegetable oils) or is a blend of petroleum-based fuel and a product obtained from biological origin or non- petroleum sources (e.g. algae, Gas-to-Liquid (GTL) process, Hydrotreated Vegetable Oil (HVO), co-processing).
An energy-rich fuel is comprised only of constituents that can be expressed as individual chemicals of the hydrocarbon family, for example alkanes with straight or branched chain and cycloalkanes, etc. An energy-rich fuel is a complex mixture that is characterized as UVCB, is formed of a relatively large amount of constituents, cannot be represented by a simple chemical structure and has a composition that may vary from batch to batch.
CARRIAGE OF ENERGY-RICH FUELS
When carrying energy-rich fuels listed in annex 12 of the MEPC.2/Circular, the requirements of Annex I of MARPOL should apply.
When carrying energy-rich fuels, the Oil Discharge Monitoring Equipment (ODME) shall be in compliance with regulation 31 of Annex I of MARPOL.
CARRIAGE OF BLENDS OF ENERGY-RICH FUELS AND BIOFUELS
The carriage provision for blends of biofuels that are recorded in annex 11 of the MEPC.2/Circular is based on the volumetric composition of the blends as follows:
Biofuel blends containing 75% or more of energy-rich fuel
When containing 75% or more of energy-rich fuel, the blend is subject to Annex I of MARPOL.
When carrying such biofuel blends, ODME shall be in compliance with regulation 31 of Annex I of MARPOL and should be approved for the mixture being transported.
When considering the deck fire-fighting system requirements of SOLAS chapter II-2, regulations 1.6.1 and 1.6.2, when carrying biofuel blends containing ethyl alcohol, then alcohol resistant foams should be used.
Biofuel blends containing less than 75% of energy-rich fuel
When containing less than 75% of energy-rich fuel, the biofuel blends are subject to Annex II of MARPOL.
With respect to biofuels identified as falling under the scope of these Guidelines, carriage requirements for specific biofuel/energy-rich fuel blends to be shipped as MARPOL Annex II cargoes will be incorporated into list 1 of the MEPC.2/Circular, as appropriate.