Supply of low sulphur bunkers and discharge of scrubber washwaters in Brazil

Supply of compliant bunkers in national ports
Even before the 2020 sulphur cap came to be, Brazilian oil giant Petrobras did already start refining bunker fuels with low sulphur levels. In October 2019, it completed the transition by further lowering the level of sulphur to meet the new international standard for low sulphur fuel oil (LSFO) stopped refining fuel oils with higher sulphur content.

Petrobras affirmed that its production capacity and logistics are more than enough to supply the domestic market and significantly increase its market share in the global bunkers market. Indeed, in February 2020, the state-owned company set a record of bunker fuel and fuel oil exports, shipping some 238,000 barrels per day, comprising over 1 million metric tons in just a month. Oil exports also remain on the high side with over 690,000 b/d exported last month amid international trade challenges such as the coronavirus outbreak in Asia, Brazil’s leading buying marketplace for oil and oil products and a key hub for global shippers and sea carriers.

Brazilian ports where bunker fuels are regularly supplied include Rio Grande*, Paranaguá*, Santos*, São Sebastião, Angra dos Reis, Rio de Janeiro*, Vitória*, Salvador*, Fortaleza, São Luís (Itaqui), Belém* and Manaus. (* by barge).

Discharge of wash water
IMO 2020 global sulphur cap is enforced through the Directorate of Ports and Coasts (DPC) Circular 7/2019. It provides that bunkers supplied to vessels in Brazil must be within the 0.5% sulphur limit and inbound ships must only burn LSFO, if not fitted with an approved exhaust gas cleaning system EGCS (scrubber), as regulated by IMO Resolution MEPC.259(68).

In the case of a vessel using non-compliant fuel oil or with a defective scrubbing system, the Port State Control will investigate the matter and may report the deficiency to the Flag State. PSC will set a term for the resolution of the problem and may detain the vessel and impose a fine, without prejudice to legal liabilities for eventual environmental damage.

While the maritime authority regulation accepts the use of EGCS as an alternative way of complying with the new regulation, it is silent on whether there is any restriction or prohibition to discharge wash water from open-loop scrubbers within Brazilian waters and, if so, what is the distance from the nearest land point where discharge is allowed.

A large bulk exporter and port operator in Brazil, recommends that vessels entering Brazilian contiguous zone (24 nautical miles from the coastline) use only compliant fuel (LSFO) and do not discharge wash waters within this range from the shore.

Until the relevant authority clarifies this issue, vessels calling at Brazilian ports are advised to switch to a closed-loop, if equipped with a hybrid scrubber, or use IMO 2020-compliant fuel while entering in national waters.

Next week, DPC will host an advisory forum to discuss ballast water management systems, LSFOs, scrubber’s wash waters, greenhouse gases, ship’s energy efficiency, and marine garbage. While it is not expected that the uncertainties surrounding the new regulation will be resolve on this event, it will certainly throw some light into the matter.

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