With only a few months before Sulpher 2020 kicks in, it’s time to make sure you know what you are doing regarding your emissions.
The new legislation is asserting that all ship fuel emissions be under 0.5% sulphur, but as we all know this isn’t a simple matter of switching from one fuel to another.
Until now, many of the high sulphur fuel oils that have been predominantly used, have a tendency to stick to the inside of the fuel tanks and pipelines causing sludge. Before you can go anywhere near changing your fuel to a compliant one, you will need to give your tanks and pipelines a thorough cleaning to ensure the new lower sulphur fuel is not contaminated in any way.
Whilst not a mandatory requirement, IMO’s MEPC 73 in October 2018 agreed that administrations should encourage ships flying their flag to develop their own Ship Implementation Plans (SIPs) in readiness for Sulpher 2020.
The various aspects you will need to consider within the implementation of your fuel switch include:
- A full risk assessment surrounding your process
- A mitigation plan considering the impact of the new fuels
- Assess and execute all fuel oil system modifications
- Any potential modifications required for your fuel oil system
- Time allocation for tank cleaning
- Fuel oil capacity
- Segregation capability
- Procurement of compliant fuel
- Fuel changeover plan.
And not forgetting the documentation of this transition of course. Although none of these processes are new to us, the expectation of a high level of cooperation with the authorities during this transition is possibly one piece of this process we daren’t ignore.
So, why do we need to clean our tanks now?
Many ships for quite a while have been using high viscosity high sulphur fuel oil, mainly due to the lower costs of these fuels. The downside to these are that they really stick to the inside of fuel tanks and form layers of semi-solid sediments and asphaltenic sludge
It, therefore, makes sense that many ship operators are now needing to clean their fuel oil tanks to rid them of these residues before putting compliant fuel into them ready for Sulpher 2020.
One of the risks of not cleaning your tanks before loading them with the new fuel is that there is a strong possibility that the residues and build-ups could dissolve and dislodge themselves into the tanks causing operational issues with filters and purifiers. In the worst-case scenario, you may be looking at fuel starvation and loss of power.
When it comes to cleaning your tanks, this is what you will need to take into account…
Manual Tank Cleaning Whilst In Dry Dock
The length of time it takes to clean your tank will vary but can usually be done in two to four days per tank.
You will also need to clean all of the pipework in the fuel oil service system by flushing it all through – this can take one to two weeks in total.
It is worth noting that a ship which has had all of its fuel oil tanks, as well as fuel system cleaned and flushed thoroughly, can start using compliant fuels straight away and will be instantly compliant.
If the fuel system hasn’t been flushed through and you have only cleaned the tanks, this can take two to five days to flush through the pipework before the new fuel can be assumed to be fully compliant with the sulphur cap.
Manual Tank Cleaning Whilst In Service
If you are cleaning your tanks manually while still in service, the risk assessment and safety measures are absolutely vital as per IMO resolution A.1050(27) on Revised Recommendations for entering enclosed spaces aboard ships.
We’ll cover this in more detail below, but this is where gas monitors such as our MGC Simple+ are crucial.
The time required to clean your tank manually will vary depending on how large your tank is and who is cleaning it.
If the cleaning is being done by the existing crew, it often takes around four days per tank, usually closer to a week for an average size tank.
If you are employing a riding crew purely to clean the tank, they can minimise the cleaning time frame substantially taking only two to four days by working in shifts.
Obviously, the tanks will need to be empty before they can be cleaned.
While the tank is empty and clean, this is a good time to check what state it is in. Use this opportunity to inspect heating coils, conduct any pressure tests needed and repair anything which requires it while it is all accessible.
If you are flushing the pipework in the oil fuel oil service system at this point, this will usually take another one to two days.
You must dispose of any residues from the tank cleaning correctly and responsibly – retain it onboard or dispose of it in reception facilities.
Using Additives To Clean Fuel Tanks
If you are looking to avoid the manual cleaning process altogether, you can clean your tanks in service using specialised additives. This is where you can add a specialist additive to fuel to gradually clean the sediments and asphaltenic sludge from high HSFO tanks.
This will need to be done in doses over a period of time before you put the first load of 0.5% fuel in and you’ll need to bear in mind that this process can often take over 6 months to be fully effective.
The Dangers Of Entering Enclosed Spaces
In terms of safety, one of your biggest considerations throughout this process needs to be the monitoring of gas when entering enclosed spaces onboard. Zone zero atmospheres require specialist gas detectors and our MGC Simple+ is designed specifically for this job. instantly guaranteeing compliance and reducing risk.
As the toughest portable gas detector on the planet, it is capable of operating in all situations. It will reliably work in Zone 0 (flammable) and completely inert (oxygen-free) environments.
The other specific benefits of MGC Simple+ are:
- NO CALIBRATION – unrivalled cutting-edge infrared sensor technology, meaning it’s immune to sensor poisoning.
- NO CHARGING – the only portable gas detector designed with 3 years of battery life, including up to 90 seconds of alarm each day so you never need to charge the detector.
- NO COSTS – absolutely no maintenance, servicing or sensor replacement.
- NO MAINTENANCE – Coming with a lifetime warranty, you can unbox and you’re good to go.
- NO LIMITS – The most robust and advanced portable gas detector on the planet. With an IP68 rating, it’s safe from the finest dust and can even be submerged under 1.5m underwater for 30 minutes.
- NO OXYGEN – It will even work in completely inert (oxygen-free) and Zone 0 (flammable) environments. Always charged, and always calibrated it is ready to go anywhere at any time.
- NO CONFUSION – Completely customisable, the sensor and alarm levels can be adjusted to suit the role required and each device can be digitally assigned to a crew member or department. Device reminders can be configured to alert crew when a bump test is required as per company standards.
One of the many challenges of running a ship is keeping on top of executing and documenting all processes, risk assessments and safety measures. Sadly, many injuries and fatalities onboard are often administrative oversight such as equipment checks being overlooked.
Incorporating totally reliable measures onboard such as MGC Simple+ is peace of mind that your crew are both safe and compliant instantly. Get in touch if you’d like to know more about keeping your crew safe in the ‘big clean’ over the next few months.