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Overcoming the Technical and Operational Challenges of Legislative Compliance

 
Embracing partnership and responsibility between fuel suppliers and ship owners
By Steffen Kortegaard, Technical Director, OW Bunker

1st January 2010 saw the official introduction of the first stringent sulphur emissions legislation within EU ports. By 2020, depending on the outcome of feasibility studies, every vessel in the commercial fleet will have to comply with a global bunker specification of 0.5% sulphur. It is a seismic change that will redefine the future of shipping.

Ten years may feel like a distant horizon and ample time for the industry to debate the concerns over the availability of distillates to meet future demand. But the stark reality is that many ship owners are already struggling to comply with the latest legislative change, let alone the ‘phased’ approach to 2020, which incorporates a further four pieces of sulphur related legislation in Emission Control Areas (ECAs), California, as well as the generic global bunker specification. It is a daunting schedule.

Despite ship owners and operators being under even more pressure from their customers to increase efficiencies, from a cost, operational and environmental perspective, they are failing to cope with the many operational challenges of switching from high sulphur, to low sulphur fuel oil. Loss of propulsion, engine failure, filter blockages, damage to auxiliary pumps are just a few of the hazards that come as part of the ‘compliancy package’.

In the current economic times, it is hassle they could well do without. And if the statistics from California are anything to go by on the back of CARB’s (Californian Air Resources Board) July 2009 low sulphur regulation, then the shipping community is in for a torrid time. Loss of propulsion incidents skyrocketed in 2009 moving from an average of 23.6 incidents per year for all of California between 2004 and 2008 to 67 in 2009.

But incidents can be avoided if a number of critical steps are observed.
Firstly ship owners and operators must view low sulphur legislative compliance with the same significance, and as part of a holistic risk management strategy. There must be an understanding of an appropriate fuel procurement strategy depending on a vessel’s trading routes, as well as the ‘green’ profile of the ship owner’s brand to determine the extent they need to go to in terms of compliance. For instance, whether they always need to purchase fuel oil with a quality of 1.5% sulphur and under, or on a less frequent basis due to the majority of travel being conducted outside of ECAs and other areas of legislation, or indeed whether they need to utilize a double fuel oil system.
Only once this is established, should ship owners and operators go through the process of understanding the potential operational challenges associated with switching fuels.

The reality is that from a technical perspective, there is much to consider. And while much can be done to mitigate potential problems, it requires a change in the relationship between the fuel supplier and the ship owner/operator. It must change from a supplier-based relationship to one of partnership, based on a mutual understanding of the challenges involved, and a focus on the effective implementation of appropriate, preventative solutions.

Developing a partnership-based relationship is not something that happens overnight. Firstly it requires a change in mindset, where, from the perspective of the supplier, the customer and the success of their operations is put first; ultimately there must be a clear understanding that their success is directly influenced by the success of their customers. Secondly, suppliers must have a total knowledge of their customer’s operations; their market and their business, as well as the strategic and day-to-day issues and challenges that they face. It is about providing knowledge, expertise and counsel that add tangible value to their operations, minimising downtime, improving efficiency and reducing operational costs. It is not just about supplying the physical product; a philosophy that we have long since advocated at OW Bunker as a drive towards embracing a more consultative and collaborative approach to working with customers.

Once this type of relationship is created, the responsibility that is required from both parties to achieve low sulphur compliance is wholly achievable. It is very easy and understandable to take a defensive position when there are operational issues; blaming quality is easy, but in the majority of cases, it is not the problem. Ultimately, switching to low sulphur fuels and distillates is a highly complex issue; it is certainly something that should have been fully understood, following the instigation of appropriate due diligence from a regulatory perspective prior to the implementation of legislation; a concept which resonates with the majority of ship owners and industry associations.

Unfortunately hindsight is a luxury that is not afforded in this scenario, and it is up to the suppliers of fuel oil who have a deep technical knowledge of the product to work with the ship owners and operators to manage the ‘switching’ process.

Understanding the risk and potential impact on the performance of diesel engines and boilers is central to instigating appropriate preventative measures.
For example, when changing fuels, the fuel delivery pump is capable of a pressure of more than 400 bar, however, the tolerance between the barrel and the plunger is very fine (1/1000 of a mm), where the maximum change in temperature can be no more than 2C. The engine fuel pump is also designed for high viscosity, heavy fuel oil for the majority of hours that it is in operation.

Therefore the challenge when switching to a low viscosity fuel oil is the risk of excessive wear, as well as ensuring that the appropriate injection pressure is maintained in the fuel pump, particularly during low load, starting the engine and when running at a low rpm. When the pumps are worn, the internal leakage can increase to a level where starting the engine is virtually impossible, because the correct pressure cannot be achieved.

Clearly viscosity and appropriate lubrication is a critical element of successfully switching to lower sulphur fuel grades. Indeed MAN Diesel recommends that prior to using distillate fuels, the lubricity is tested by an HFRR (High-Frequency Reciprocating Rig) test. This can be performed by an independent laboratory,
according to ISO 121156-1 standards, which dictates that the maximum wear scar diameter should not exceed 460 mm.

The low viscosity of distillates and low sulphur fuel grades can also impact technical equipment such as gearless screw spindle pumps, which can suffer serious wear problems and subsequent damage. This can be a significant safety problem for tankers producing inert gas while operating their cargoes.

Auxiliary engines designed for heavy fuel oil operation might also face problems with the fuel equipment due to the discrepancy between sulphur content and lube oil alkalinity. It is therefore critical that ship owners and operators consult their lube oil suppliers, as the BN number should correspond to the new fuel conditions.

There are a number of other possible challenges; the engine can stop, or not start, there could be a fluctuation in the engine revolutions, damage to the fuel and auxiliary pumps, or the filter could be blocked. Identifying potential problems before they happen and implementing appropriate solutions are central to minimising downtime and saving costs. This includes ensuring that the fuel pumps are of a good quality and appropriately cooling the gas oil, as well as implementing the right training procedures for crews. It means ensuring that there is a good length of time between changing the fuel oil and gas oil and analyzing the filter pressure, as well as only using duplex filters and making sure that there is compatibility with the blended fuels. It means fitting a cooler with sufficient capacity in the low viscosity line and frequently testing pumps for leakages, as well as being able to understand and identify unusual noises that might signal a problem.

The same principals of risk should be applied to boilers when changing to distillates and low sulphur fuel oils; the potential for a low flash point, filter blockages, or damage to auxiliary pumps. And similarly there needs to be a knowledge of the potential solutions; never taking on bunkers where the oil cannot be stored with a 15 C safety margin; fitting a flame screen onto the rotary cap burner; fitting a heat exchange steam injection burner; ordering fuel oil and distillates with a high enough flash point; ensuring that the cooler is fitted with sufficient capacity in the low viscosity line; frequently testing the pumps for internal leaks by closing the valve on the pressure side and making sure that the pump provides enough pressure to open the safety valve; and of course ensuring that the crew are appropriately trained to deal with the technical challenges.

When a ship owner’s primary goal is servicing their customers and getting goods where they need to be as efficiently as possible, worrying about technical and operational issues associated with legislative compliance can be a costly distraction. And while the supply and procurement of fuel is viewed as a commodity market, it does not mean that suppliers should just abandon their customers once the product is delivered. If there is an opportunity to add value based on the knowledge and technical understanding of the product, and to provide advice and counsel that enables ship owners and operators to maintain and improve their levels of efficiency, and increase their competitive advantage, it must be taken. It requires a change in the relationship and shift in mindset where partnership, responsibility and collaboration are embraced, and most importantly, where the customer is put first.

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