There are fears among experienced mariners that there will be a surge in loss of propulsion (LOP) incidents in 2015 because of the number of ships that will be switching from heavy fuel oil (HFO) to distillates upon entry into emission control areas (ECAs).
As previously reported on Bunkerworld, the number of ships reporting LOP in Californian waters rose sharply from July 2009, when the Air Resources Board began requiring ships to switch to distillate fuels within 24 nautical miles (nm) of the California coastline.
According to US Coast Guard (USCG) statistics, reported LOP incidents in Californian waters jumped from 26 in 2008 to 67 in 2009. Even higher numbed have been seen later.
A USCG notice dated September 9, 2014, said there were 93 LOP incidents in District Eleven (California) during the past year, and that 15 of those (16%) were related to fuel switching.
If translating the Californian numbers to the ECA entrance at the southern end of the English Channel, a frightening scenario emerges.
Annual vessel movements in the Californian waters in 2013 numbered just over 8,000, of which 0.95% suffered LOP incidents and 0.17% were firmly linked to fuel switching, former mariner Captain Francois Abiven, who now works with an oil major in France, told Bunkerworld.
Meanwhile there are around 60,000 annual vessel transits in and out of the southern entrance of the English Channel, the North Sea and English Channel ECA border.
If 0.17% of these vessels were to suffer a fuel switch related LOP, that could translate to 102 incidents per year, on average one such event every three days. If considering all LOPs, some 570 annual incidents may be expected.
Adding to the concern is that the new ECA sulphur limit takes effect from January next year, when operations in harsh weather conditions tend to both increase the risks of LOP incidents overall and heightens the risk of catastrophic consequences.
Captain Abiven told Bunkerworld he though it was "complete madness" that the change in the ECA sulphur limit from 1.00% to 0.10% had been timed to the middle of winter. He expressed surprise and disappointment that this had not been considered by the International Maritime Organization (IMO) at the time of adoption of the revised MARPOL Annex VI, which determines the ECA and global sulphur limits.
If a ship were to face LOP in the English Channel area, there are only three tugs on standby to offer assistance, two in France and one in the UK, according to Captain Abiven.
Many of these ships carry dangerous goods, and according to Captain Abiven’s calculations, 102 LOPs per year in the English Channel would equate to some 605,000 tonnes of dangerous goods set adrift on ships without engine power.
He stressed the importance of applying good technical solutions to fuel switching onboard ships, focus on crew training, and to disseminate information to prevent major ship disasters resulting from LOP incidents in the new year.
Alternatively, he recommended: "Sell your tourism assets in Brittany and invest in salvage towing companies."
There are suspicions in the market is that a lot more LOP incidents are related to switching from HFO to distillate fuel than those specified as such. Iain White, Field Marketing Manager at ExxonMobil Marine Fuels & Lubricants also emphasised the fuel switch risks in an interview with Bunkerworld last week, mentioning the surge in LOP incidents in California as evidence the problem was significant.
Bunkerworld contacted Captain Jeff Cowan, Oil Spill Prevention Specialist, Office of Oil Spill Prevention and Response at California Department of Fish and Wildlife to see if he could explain LOP statistics reported by is department, based on USCG reports. Most LOP incidents do not have a reason mentioned, while some are reported to relate to fuel switching and others as "Suspect Fuel Related".
He explained that USCG LOP investigation reports came up with the "suspect" designation because items that failed were in the fuel system. He also explained a few of the technical causes for LOP, including mechanical failures that can be attributed to lack of maintenance, which can exacerbate fuel system leakage when switching from HFOs to distillates. Another type of LOP often reported in Californian was an "Increase in Failure to Start scenarios," typically the result of the difference in British Thermal Units (BTU) of the distillate fuel versus the HFO.
A number of issues associated with switching from HFO to distillates can cause LOP, due to a lack of operational procedures in ship manuals, Captain Cowan explained. On the basis of his summary of LOP causes, it did seem possible that some of the LOPs that were not directly associated with fuel switching in USCG data could nevertheless have been linked to it.
Despite evidence that there is a risk, the US Environmental Protection Agency and the USCG have not carried out any risk assessments with regard to mandatory fuel switching.
LOP incidents in Californian waters have so far fortunately not resulted in any groundings or collisions, but Captain Cowan has pointed to more alarming risks from the potential number of LOP incidents in the Gulf of Mexico, where a huge number of oil rigs are found in close proximity to shipping lanes.
He has also noted the risks related to ship arrivals into the North Sea, where there are around 570 oil rigs, and the English Channel. By his estimates, there could be 646 LOP annually in the crowded English Channel if they occur in the same proportion as in California.
Ships arriving into the US and Canada will be required to undertake the switchover 200 nautical miles from the shore in the open sea, which could be good news for California as fuel switches will take place at a safer distance from shore. By contrast, the English Channel and North Sea bound ships will be in close proximity to France, the UK coast and oil rigs when undertaking the switchover, Captain Cowan mentioned.
All the problems associated with fuel switching can be easily prevented with pre-planning, awareness training and practice, and investing in replacement of worn fuel system components, Lloyd's Register - FOBAS Product Manager, Timothy Wilson, told Bunkerworld in July.
Francois Abiven and Captain Cowan were also advocating awareness of solutions and advice on how to manage the ECA fuel switchovers without incident.
Likewise, the USCG said in its recent notice that "planning an preventative maintenance are critical to the proper operation of a vessel’s main engine and prevention of losses of propulsion."
One oil major's shipping arm told Captain Cowan that "fuel cooler/chillers installed in the fuel system aboard their ships have alleviated all of the issues described previously."
But with the ECA sulphur limit change occurring in winter, when it is windier and waves are bigger in the North Atlantic and North Pacific, ships are already at greater risk of suffering LOP, according to Captain Cowan.
As the likelihood of suffering a LOP incident is increased "many times over" when using distillates, he and others are anxious about what 2015 might bring.