Switching Fuels Safely: A Guide to Preventing Loss of Propulsion after Fuel Switch to Low Sulfur Distillate Fuel Oil

By Jeff Cowan

The California Air Resources Board (ARB) created regulations for vessel emissions reductions for California waters as part of its continued mission to improve air quality around the state. The new requirements came into effect in July 2009, under California Code of Regulations (CCR), Section 2299.2, Fuel Sulfur and Other Operational Requirements for Ocean Going Vessels within California Waters and 24 Nautical Miles of the California Baseline.

The regulations require that vessels burn either marine gas oil (MGO) with maximum 1.5% sulfur, or marine diesel oil (MDO) with maximum 0.5% sulfur, in their main and auxiliary engines. Following the implementation of the regulations, California witnessed a 100 percent increase in loss of propulsion (LOP) incidents within state waters during 2009. In 2010, California saw 54 LOP incidents compared to 24 in 2008 (the last full year before ARB regulations took effect).

The LOPs can be loosely categorized into six groups for ease of discussion.

Group 1
In Group 1, engine failures resulting in the LOP are due to the inability of the main engine, operating with MGO/MDO, to overcome the forces on the propeller from the forward momentum of the ship. The engine may turn over at higher RPM and initiate combustion; however, as the engine reduces speed to come to dead slow or slow astern there are not enough BTUs in the fuel to maintain engine inertia. The engine stalls with the subsequent loss of propulsion.

Similarly, a ship not getting engine starts while anchoring when an astern bell is given, typically initiates a "Failure to Start" scenario. The remedy to the lack of BTUs is to adjust the fuel rack to allow more fuel into the cylinder. This procedure cannot be done from most ship bridges but only from the Engine Control Room or from the Engine Side (manual).

Group 2
In Group 2, failures resulting in the LOP are due to problems with controlling the temperature of the MGO/MDO. Each engine has specifications as to the temperature range required to operate using either heavy fuels or lighter fuels. For example, the optimal temperature range for an engine might be 1,350 °C for a heavy fuel oil (HFO) and 400 °C for the MGO. Because heavy fuels must be heated (for the right viscosity to burn) and lighter fuels may not need to be heated, there are problems associated during the fuel oil switch over in both heating and cooling the different fuel oil systems (since the fuel oil is supplied through the same auxiliary systems). Heating an MGO/MDO may cause ‚"flashing‚" of the lighter fuel oil to vapor. The fuel injectors would not work when the fuel flashes causing a loss of power in that cylinder. Multiple cylinder flashes could result in LOP.

Group 3
In Group 3, failures resulting in a LOP are associated with the loss of fuel oil pressure to either the fuel pumps or fuel injectors. The loss of pressure could be a result of many factors including wrong control set points, use of bypass valves, inoperable equipment, inattention to operating conditions, or excessive leakage through ‚"O" rings and seals.

The problem lies with physics. Metal expands when heated and contracts when cooled. Ships evolved to burn the heaviest and cheapest fuel available, HFO. To utilize the HFO on ships, the fuel is heated to as much as 1,500 °C to get it to flow. In comparison, MGO/MDO fuel is burned at ambient engine room temperature or 400 °C and no heating is required. Once the cooler MGO is introduced into the fuel pumps and injectors, they contract causing a loss of fuel pressure at the pump with marginal spray pattern and leaks at the injector.

One of the other issues using MGO in an engine that has successfully run HFO for some time is viscosity. Typically the engine manufacturer's recommended minimum viscosity is 2 centistokes (cst). Fuel viscosity specifications at 400 °C temperature for MGO/MDO range from 1.5 to 6.5 cst. The MGO loaded in California has a viscosity of 2 to 3 cst at 400 °C. When the temperature of the MGO is increased into an already warm engine that just ran on HFO, the heat lowers the viscosity causing the fuel machinery parts to bind or break. Keep in mind that the cylinder temperature is usually maintained at 800 °C and this heat migrates into the fuel lines as well.

Unsurprisingly, the introduction of distillate fuel into the fuel system causes leaks – sometimes excessive leaks. With MGO/MDO there is a very real risk of external combustion or fire. Replacing "O" rings at the manufacturer's recommended intervals has proven not to be adequate. For example, in the case of injector "O" rings on a particular ship, the manufacturer suggested interval for replacing fuel injector "O" rings is 10,000 hours. The engineers on this ship found an interval of 2,000 hours was more appropriate to change injector "O" rings to prevent potential fire hazards. These fuel leaks tend to disappear when engines are switched back to the heavier fuel oil.

Group 4
In Group 4, failures resulting in LOP are associated with the loss of fuel oil pressure or the loss of flow in sufficient quantities to maintain operation. Strainers and filters, or the lack of a strainer and filter, contribute to clogging or restrictions in the fuel oil supply system.

The MGO/MDO acts as a solvent causing a de-coking effect, clogging fuel filters. This is due to burning a lower grade of HFO that has excessive amounts of asphaltenes. These asphaltenes adhere to the inside of the fuel lines and assorted other fuel components. When MGO is introduced the asphaltenes are released, collecting in the fuel filters/strainers.


Group 5
In Group 5, failures resulting in the Loss of Propulsion appear to be associated with problems in either the starting air system or the control air systems. Problems with starting air systems are not fuel related and only need to be mentioned as a cause of LOPs.

Group 6
In Group 6, failures resulting in the Loss of Propulsion appear to be associated with mechanical failure not associated with other groups.

Having defined the groups of LOPs, the intent of this guide is to reduce the Loss of Propulsion incidents occurring within the state of California boundaries. The time to deal with problems aboard ship is either miles out at sea or alongside the dock. Not in Maneuvering/Pilotage waters!

Many of the LOP incidents that occurred in 2010 involved "First Timers" (ships making first entry into California waters since July 2009). Since California sees one or two first timers per week, based upon my knowledge and experience, the Office of Spill Prevention and Response (OSPR) decided to provide suggestions for ships working with low sulfur distillate fuel oil (LSDFO).

Initial Entry
For vessels intending to enter the California ARB Emissions Control area for the first time since July 2009, I recommended and California advises the crew should conduct a “Trial” (actual) fuel switching within 45 days prior to entering California waters. Run main and auxiliary engines no less than four (4) hours on low sulfur distillate fuel (LSDFO). This will help identify any specific change over or operational issues or problems.

If ships perform a trial fuel switch, the operators will be more able to avoid problems that could occur versus learning underway upon entering California waters and not knowing the sundry issues. Forty-five days was chosen based upon an understanding of containership operations, where schedule is everything. Somewhere within that schedule there is always time to perform a trial maneuvering and 45 days should allow the ship's personnel to experience the fuel switchover and document remedial fixes, if any, mitigating Groups 1,2,3,4.


Repeat and Initial Entry
Part One- Training: Within 45 days prior to entering the waters of California it is strongly advised ship engineers should exercise:
A. Operating main engine from the engine control room.
B. Operating main engine from engine side (local).
Crew should become familiar with "Failure to Start" procedures while maneuvering and establish corrective protocols for ‚"Failure to Start" incidents.

Following, the "Perfect practice ensures proper performance" creed, if the bridge and engineering crew is practiced in the event of a "Failure to Start" scenario, they will perform satisfactorily when called upon in the event of a real failure. This is especially important in maneuvering/pilotage waters.

The air and fuel in the start sequence can be adjusted in the engine control room and at engine side. These items cannot be adjusted from the bridge on most ships; hence, the provision of the advisory/guide establishes protocols for dealing with the “Failure to Start” scenario as outlined in LOP Groups 1 and 2.

Too many ships have run out of "start air" because they continue to initiate starts from the bridge where control of the fuel rack and amount of air for starting cannot be adjusted.

Part Two- While Underway after Fuel Switching Completed (HFO to LSDFO): Ships should ensure one of the senior engineering officers is in the engine control room while the ship is in pilotage waters to be able:
1. To operate the ship main engine from the engine control room.
2. To operate the ship main engine from engine Side (Local).
Special Attention should be paid to International Standards of Training, Certification and Watchkeeping (STCW) Rest Requirements.

While interviewing Chief Engineers (CE), I found they were putting in excessive hours. CE's are not subject to the STCW rest requirements as they are non-watchstanders. However the CE is human and subject to fatigue just as junior officers. It has been proven too many times that fatigue can cause errors in judgment which could contribute to a LOP incident.

Usually the Senior Engineers consist of the CE and Second Engineer on internationally flagged ships while CE and First Assistant Engineer (on US flag ships) have the most experience with the ship engine operation. If the CE is comfortable with anyone substituting on duty, it is usually the other Senior Engineer. Hopefully, a substitution will allow the CE some rest. Some ships have the CE down in the engine room for the fuel switchover, then the CE retires for rest while assigning the other Senior engineer to standby in the Engine Room, mitigating Groups 1 through 6.

Part Three- Engine Guidelines: The following Engine Advisory Guidelines were taken from the US Coast Guard MSA 03-09 with additions and clarifications from industry partners.

• Consult engine and boiler manufacturers for fuel switching guidance.
• Consult fuel suppliers for proper fuel selection. Exercise strict control when possible over the quality of the fuel oils received.
• Consult manufacturers to determine if system modifications or additional safeguards are necessary for intended fuels.
• Develop detailed fuel switching procedures.
• Establish a fuel system inspection and maintenance schedule.
• Ensure system pressure and temperature alarms, flow indicators, filter differential pressure transmitters, etc., are all operational.
• Ensure system purifiers, filters and strainers are maintained.
• Ensure system seals, gaskets, flanges, fittings, brackets and supports are maintained.
• Ensure that the steam isolation valves on fuel lines, filters, heaters etc. are fully tight in closed position while running LSDFO.
• Ensure that the fuel oil viscosity and temperature control equipment is accurate and operational.
• Ensure detailed system diagrams are available and engineers are familiar with systems and troubleshooting techniques.
• Ensure Senior engineers know the location and function of all automation components associated with starting the main engine.

California hopes that ships choosing to use these guidelines will alleviate some of the LOP incidents occurring within the waters of California. I believe that it will only take one LOP incident to change lawful maritime trade internationally. So on behalf of my sea-going brethren, any reduction of a Loss of Propulsion incident is one less chance of catastrophe.

Captain Jeff Cowan sailed aboard various containerships as Master, capping a 35 year seagoing career. He now works for the State of California, Office of Spill Prevention and Response where his experience at sea and onboard vessels helps California make sound recommendations to industry.

Arbitrator Orders Striking ILWU Members Back to Work

Most, but not all, of 700 dockworkers have returned to work at the ports of Los Angeles and Long Beach after walking off the job last week as part of a strike organized by the clerical unit of the International Longshore and Warehouse Union.

The members of ILWU Local 63 picketed four terminals at the ports on Dec. 2 in response to an impasse in contract negotiations that has left the union members working without a contract for 17 months.

The strike only lasted one day, however; hours after picket lines went up, an arbitrator ruled against the labor action and ordered that work resume, which it did during the 6 pm evening shift.

The union has appealed the arbitrator’s decision, according to ILWU spokesman Craig Merrilees. In the meantime, some workers continued picketing on Mon., Dec. 5. The ports’ longshoremen are bound under a separate labor agreement and not participating in the clerks’ labor actions.

The union local targeted three facilities at the Port of Los Angeles for the work stoppage: terminals used by NYK Line, Evergreen and China Shipping. At the Port of Long Beach, picketers targeted the Hanjin Shipping terminal.

The contract between the union and Los Angeles/Long Beach Harbor Employers Association expired July 1, 2010 and the two sides have not been able to come to an agreement on a new one since then.

One of the main sticking points cited by both sides is the implementation of new technology that could potentially result in the elimination of union jobs.
No new negotiations are currently scheduled.

Radioactive Goods Found at 2 Canadian Ports

The Canada Border Services Agency says it has intercepted more than a dozen marine containers from Asia that have tested positive for low levels of man-made radiation at two Canadian ports over the past two months.

The first container contaminated with Cobalt-60 was identified at the Port of Vancouver on Oct. 3 according to the CBSA. Since then, 19 marine containers contaminated with Cobalt-60 have been intercepted and detained at the Port of Vancouver and Port of Prince Rupert.

“Through the use of radiation detection equipment and the efforts of CBSA officers, the presence of goods contaminated with the radioactive isotope Cobalt-60 were identified and detained,” Canadian Minister of Public Safety Vic Toews said in a statement.

Cobalt-60 is a synthetic radioactive isotope used to sterilize medical equipment and also has various uses in laboratories. Cobalt-60 is known to cause cancer in people exposed to it for a lengthy period of time.

Radiation detectors were first installed at the Port of Vancouver by the federal government in 2007, and can scan up to 100 percent of incoming and outgoing containers.
The government increased radiation monitoring at the port in early 2010 over fears that terrorists could try to sneak a nuclear device into the country to detonate during that year’s Winter Olympics.

Port of Coos Bay in Negotiations for Coal Terminal

The Port of Coos Bay is in talks with a shipper regarding the possibility of bringing a coal export terminal onto its property to export anywhere from six to 10 million thermal tons of coal annually to Asian countries.

The port hasn’t publicly revealed the name of the shipping company. Port CEO Jeff Bishop has said that such a terminal could aid in the funding of other regional developments, such as improvements to the Coos Bay Rail Link.

Railroad service was recently restored to the Coos Bay area, but according to a report by Bishop, the Coos Bay Rail Link would need “huge” capital infrastructure improvements before it could accept cargo trains on anything more than a very limited capacity.

“Any projections … regarding railcar volumes are premature, especially due to the traffic capacity constraints on the Coos Bay rail line,” the report reads in part. “The rail line has finite capacity. This differentiates us from other proposed coal terminals located alongside major railroads.”

Currently, the only coal export terminal on the West Coast is in British Columbia.

Environmental group the Sierra Club has already expressed opposition to the possible terminal, saying that the addition of mile-long coal trains would have an adverse affect on vehicular traffic, plus create environmental, safety and health hazards.

The arrival of one coal train per day would create 100 ship calls per year, Bishop said.

Port of Longview Approves Landmark Budget

The Port of Longview on Dec. 2 approved a 2012 operating budget of $32.3 million, which includes a projection of over $30 million in revenue for the first time in the port’s history.

The budget calls for $16.6 million in operations spending next year, a four percent rise from 2011; as well as $2.3 million in capital expenses, including a substantial increase in longshore labor, which the port anticipates will be needed with the launch of grain exports next year.

The port expects to finish 2012 with $4.5 million in net income, which it plans to put in reserves help pay for capital projects like buying new terminal equipment.

About $1.57 million in property taxes is expected to be collected next year; just last month the port commission voted to cut the property tax levy to 22 cents per $100,000 valuation, a decrease from the current 39 cents per $1,000. For a home valued at $150,000, the owner will pay $33 annually in property taxes to the port, as opposed to $59 in property taxes in 2011.

The budget also includes three percent raises for the port’s top three salary-earning employees, executive director Ken O’Hallaren, facilities director Norm Krehbiel, and terminal operations director Doug Averett, who are all slated to make between $110,000 and $135,000 in 2012.

Judge Considers Dropping ILWU Criminal Charges

International Longshore and Warehouse Union lawyers have asked a judge to drop criminal charges against several dozen dockworkers who blocked a train from entering a Port of Longview terminal during a September protest.

Attorneys for union members argued in Cowlitz County District Court on Nov. 30 that the dockworkers’ actions were protected under the US constitutional amendment protecting the right to assemble.

“They were doing something very important to Americans – engaging in First Amendment action,” ILWU attorney Neil Fox told district court judge Ron Marshall during the hearing.

The lawyers also asserted that the port did not clearly identify which areas were off-limits during the protest.

Almost two-dozen people were arrested on misdemeanor charges during the Sept. 7 demonstration, which included a four-hour standoff where about 300 dockworkers and supporters stood on the railroad tracks below an overpass and blocked a mile-long train bound for the port’s EGT terminal.

In addition to the arrests, the union was fined more than $300,000 by the federal government for blocking of trains and alleged property damaged caused during a total of three protests that took place during September. The union is appealing the fines.
The protests were part of a long struggle between the terminal operator and union over labor issues.

The union says its contract with the port requires that the 25 to 35 jobs inside the terminal must go to unionized labor. The company, however, says its lease agreement with the port does not require ILWU workers.

During the Nov. 30 hearing, Marshall didn’t indicate when he might issue a ruling, but said a lack of proof by prosecutors may play a part in his decision.
“We’re still in flux in terms of whether the state has admissible evidence to prove a crime,” he said.

West Coast Ports Bracing for Possible Occupy Shutdown

Ports up and down the West Coast say they are preparing for the possibility of a mass demonstration later this month, even as the union representing longshore workers says it won’t support the protest.

Officials with the ports of Los Angeles, Long Beach, Oakland and elsewhere all say they are mapping out strategies to deal with the expected demonstration, which is planned for Dec. 12 by the Occupy movement.

The movement, which protests wealth inequality, already succeeded in a port protest on Nov. 2, when thousands of demonstrators managed to shut down the Port of Oakland for about four hours.

Now the movement says it will expand its actions to include ports from Vancouver, Canada down to San Diego during a one-day action, starting at 5 am on a Monday. If it transpires, the effect could be temporarily devastating, particularly at LA/Long Beach: the port complex handles an estimated $1 billion in imports and exports daily.

Occupy has specifically said it is targeting terminal operators EGT and SSA, because of perceived mistreatment of workers in South America and of ‘gross exploitation’ of port truckers.

“EGT … is Wall Street on the waterfront,” Barucha Peller of the West Coast Port Blockade Assembly of Occupy Oakland said. “This is our coordinated response against the (top) one percent (of the wealthy). On Dec. 12, we will show our collective power through pinpointed economic blockade.”

But despite previously expressing written and verbal support for the movement, ILWU leadership says it does not authorize dockworkers’ participation in the planned shutdown because it is by a third-party group and has not been vetted by the union.

Port of Grays Harbor Vehicle Exports on Record Pace

The Port of Grays Harbor says it’s on pace to set a new record for the number of vehicles exported this year. The increase, the port says, is due to a growing demand in Asia for US-made vehicles.

Through October, more than 30,000 North American-made vehicles have been shipped through the port, already surpassing the roughly 21,000 that passed through during all of 2010.

The port estimates it’s on pace to see about 37,000 cars shipped out during the year, with the prime destination being China, which has become the world’s largest automobile market. Demand for North American-made cars, particularly Chryslers, has exploded in the country in recent years and is expected to rise 10 percent in 2012.

The port’s export business, which was launched in 2009, is handled by Pasha Automotive Services, which receives the vehicles after they’re delivered to the port via BNSF and Union Pacific railways from Midwest assembly plants.

Port of Seattle Budget to Rise in 2012

The Port of Seattle Commission has formally approved a 2012 budget that includes increases in the amounts of both operating revenue and operating expenses.

The budget, approved by the commission at its Nov. 22 meeting, includes an operating expenses increase to $309.7 million, an 8.4 percent jump over the current year. It also includes an operating revenue rise to $518.1 billion, up 5.1 percent compared to 2011.

Operating revenue for the port’s real estate division is expected to grow by about two percent compared to 2011 budget levels, according to budget data, as third party and lease revenue rises slightly as the hospitality and real estate markets continue to recover.

CEO Tay Yoshitani said that in 2012 the port expects an increase in cruise passengers as well as a new lease at Terminal 106 to increase operating revenues 2.5 percent relative to 2011.

The addition of a Disney Cruise Line homeport ship is anticipated to increase passenger volumes by about 10 percent, he said.

Critical goals for 2012 listed by port include increasing the amount of cargo freight and number of passengers moving through the freight and passenger terminals, as well as developing a stewardship plan for key division assets, such as the SeaTac Airport, which the seaport operates.

The budget also allocates over $390 million for capital projects, including the Alaskan Way viaduct replacement project and South Park Bridge.