USCG Marine Safety Alert
The U.S. Coast Guard issued a marine safety alert today to remind vessel owners and operators to establish effective fuel oil changeover procedures during efforts to comply with MARPOL Annex VI emission regulations. The USCG said that several recent incidents of fuel leakages during changeovers prompted the alert.
The USCG cited multiple unspecified incidents involving substantial machinery space fuel leakages that occurred while vessels were switching fuel oil to ultra low sulfur (ULS) fuel oil to ensure compliance with MARPOL Annex VI, Regulation 14.3.4. The new regulations, which came into effect on January 1, lowered maximum fuel sulfur content from 1.0% to .10%.
The USCG said all leakages were contained, but warned that fuel releases of any kind can result in pollution, shipboard engine room fires, and injury or death of personnel. The USCG also added that many losses of propulsion have occurred in different ports associated with changeover processes and procedures.
Each ship which uses higher sulfur content fuel oil is required to develop and implement changeover procedures for switching between residual and distillate fuels in accordance with MARPOL Annex VI, Regulation 14.6, the USCG said.
The new regulations require that the 0.10% fuel sulfur content must be used the entire time a vessel is operating in the North American and U.S. Caribbean Sea Emission Control Areas (ECA). As a result, vessels using higher sulfur content fuels must change to ultra low sulfur (ULS) fuel oil to comply. The vessels must use the ULS fuel oil on inbound and outbound transits, at the dock, and anytime within the ECA. Meeting this requirement requires planning and analysis before any changeover from higher sulfur content fuel oil to ECA compliant fuel oil and vice-versa.
In some cases vessels may require fuel oil service or day tank modifications and fuel oil service piping modifications to facilitate safe procedures and compliant fuel operations within the ECAs. The management and oversight of any fuel oil mixing that may be part of a changeover process must take place before the vessel enters the ECAs or after the vessel leaves the ECAs. The amounts of ULS fuel oil onboard must be enough to satisfy the vessel’s fuel demand at all times while the vessel operates within the ECAs or efforts should be made to take on additional ULSF while in port.
The Coast Guard included a list of recommendations for vessel owners and operators in the alert, which are printed below.
- 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.