The Steamship P&I Club has issued a Risk Alert regarding Ultra Low Sulphur Fuel Oil Change-over Procedures. The Club warns that some boilers may not have been originally designed to burn lighter fuel types and may need modification.
From 1 January 2015, for ships without an approved and effective exhaust gas scrubber operating within an Emission Control Area (ECA), the sulphur content of fuel oil used should not exceed 0.10% by mass (10 ppm). All main and auxiliary engines and boilers are affected by the Regulation, meaning that vessels using heavy fuel oil must have completed the change-over process and operate on ultra-low sulphur fuel upon entering an ECA.
Note: Prior to 1 January 2020, the sulphur content limit of fuel oil shall not apply to ships operating in the North American ECA or the United States Caribbean Sea area that were built on or before 1 August 2011 and are powered by propulsion boilers that were not originally designed for continued operation on marine distillate fuel or natural gas.
Ships operating within the European ECA have become familiar with existing European legislation where the maximum sulphur content of fuels used by ships at berth has not been allowed to exceed 0.10% by mass in EU ports since the 1 January 2010 unless the vessel was:
- Due to be at berth in a port that lies outside of the ECA for less than two hours;
- Planned to use only a shore based power supply.
From January 2015 Members choosing to continue to trade within an ECA and who have not fitted an exhaust gas scrubber will have to consider important factors including, the calorific value, decreased viscosity and lower flash point of distillate fuel such as MGO in comparison to IFO
The manufacturers of the engines, boilers and/or control system should be consulted regarding possible modification. Modern boilers may not have been originally designed to burn lighter fuel types such as MGO and may need modification of the burners and control systems requiring, if applicable, approval of the class society.
If the operator is satisfied that, modifications to the vessels’ installed equipment and systems are not required then evidence of such an evaluation should be carried on-board to satisfy the safety requirements of ISM, Port State Control and possibly Charterers.
The Club recommends the folowing:
- Boilers cannot sustain use of MGO during normal operation to meet the normal demand without modifications.
- Explosion can take place due to incorrect operations such as improper purging before ignition.
- Following flame failure fuel may fall on hot surfaces leading to explosion. All possible causes of flame failure, including actual change-over of fuel types should be considered.
- Steam atomisation may not be suitable leading to flame instability, improper combustion, and possibly flame failure.
- Use of MGO may cause coke deposits on rotary cup types of burners. Protective heat shields may be necessary to prevent coke build up.
- Existing burners may have to be modified or burner assemblies suitable for both HFO and MGO may need to be fitted.
- Existing piping used for heated HFO from the pump to the boiler may not be suitable for MGO.
- Where a boiler is designed to burn HFO instead of MGO, a flame failure may occur when the fuel is changed over to MGO.
- HFO is more viscous than MGO and existing pumps may have difficulties with suction of the lighter oil. As HFO has better lubrication properties than MGO, overheating of pumps could occur.
All equipment manufacturers concerned should be consulted to determine the necessary safeguards. A detailed fuel change-over operation manual should be readily available for the operating crew on board.
For further information please contact the Loss Prevention Department, Steamship Insurance Management Services Ltd [email protected]
Click here to read Club’s Risk alert on fuel oil change over procedures
Source: The Steamship P&I Club
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