Web alert: US Coast Guard issues Safety Alert regarding Fuel Oil Changeover Procedures
06 March 2015
A previously reported in the club’s web alerts dated 20 January 2015 and 16 January 2015, the North American Emission Control Area (ECA), under the International Convention for the Prevention of Pollution from Ships (MARPOL), came into effect on 1 August 2012, establishing strict controls on emissions of sulphur oxide (SOx), nitrogen oxide (NOx) and particulate matter for ships trading primarily off the coasts of Canada and the United States. Since 1 January 2015, the sulphur content of fuel oil burned within the ECAs must be no more than 0.10% m/m.
The US Coast Guard (USCG) issued a Safety Alert on 3 March 2015, regarding ultra-low sulphur (ULS) fuel oil changeover procedures and compliance with MARPOL requirements. In this Safety Alert, the USCG notes that several incidents have been reported involving substantial machinery space fuel leakages which occur while vessels switch fuel oil. USCG said fuel tank modifications, proper management of fuel mixing and temperatures, and ensuring sufficient supplies of ECA compliant fuel may all form part of adequate switchover procedures. Furthermore, the USCG advised all ship owners to note the important technical issues that have been highlighted by classification societies, insurers, and industry associations. The Safety Alert provided links to a few of the documents.
Importantly, the USCG recommended the following to all ship owners and operators:
Ensure fuel oil switching is accomplished outside of busy traffic lanes and the ECA. Generally the ECA is 200 nm from the North American Coast and 50 miles from the U.S. Caribbean coast (e.g., the Commonwealth of Puerto Rico and the U.S. Virgin Islands);
Utilize their technical resources to develop safe operations and maintain full compliance with emission requirements;
Consult with engine and boiler manufacturers for fuel oil changeover guidance and to determine if system modifications or additional safeguards are necessary;
Consult fuel suppliers for proper fuel selection;
Ensure all sensors, controls and alarms – pressure, temperature, viscosity, differential pressure, flow indicators, etc., are operational and function as designed;
Ensure system piping, seals, gaskets, flanges, fittings, brackets, etc., are maintained;
Ensure detailed system schematics are available;
Review and update fuel oil changeover procedures as needed;
Establish a fuel oil system inspection and maintenance schedule;
Review and update fuel changeover procedures based on lessons learned;
Provide initial and periodic crew training for accomplishing safe, effective and leak-free fuel switching;
Remember that the energy content of a given volume of ULS fuel oil may differ from residual fuel, such that existing throttle settings may not give the desired propeller shaft RPM or generator loads and performance/speed trials on ULS fuel oil may need to be conducted;
Anticipate that there may be many technical challenges for operators when beginning to use ULS fuel oil as a matter of routine and compliance. These range from excessive leakages of fuel system components, increased wear and tear on these components, lack of lubricity of the fuels and the need for possible changes in maintenance schedules, operational methods, etc. The link below provides additional information on this topic.