Answer SSEP Question 39
Q39.
Your ship entering SECA zone, you have changed over from high sulphur
to low sulphur fuel oil. On arrival Port State authority boarded your
vessel and took sample and proved you have violated the relevant
regulations of MARPOL regarding sulphur limits as prescribed. Write a
statement, stating what are the possibilities of incorrect change over
process or incorrect sampling process.
Answer : Possibilities of in correct change over process
(a) Changing over front HSFO to LSFO shall be done In accordance to ship board SMS procedure.
(b) The time to commence the C/O process purely dependent on the load on the engines and the consumption rate. If the engines (Main & Auxiliary) are running at full load hence the consumption is higher, it takes lesser time for the LSFO to be in the system and flushed completely.
1. The time given for the changeover process was too small and the residue of HSFO persisted in the system.
2. The mixing column OR buffer tank return line shall be changed over LSFO tank only after the changeover process is completed and LSFO is seen on the eight glass or through test cock. If the return is changed over inappropriately the LSFO tank gets contaminated with HSFO from the system.
3. All standby engines shall be started in order to be flushed with LSFO and to remove HSFO from their system completely. If standby engines are not started during C/O process the residual fuel when mixed with the LSFO will have, higher sulphur levels in the sampling.
4. The fuel skid (Fuel preparation circuit) containing filters, feed pump, automatic filters, heater, viscotherm, Flowmeter shall be thoroughly flushed with LSFO, Here the main contamination spot is the standby pumps which are usually not run during C/O process will contaminate the system.
5. Fuel transfer system if uses the same line and pumping arrangement, then the system shall be flushed adequately with LSFO to ensure they are free from any HSFO residues! If not flushed adequately there are chances for the LSFO tanks to be contaminated.
Possibilities incorrect sampling process
1.Representative sampling point Proper sampling point would be the fuel inlet to the engine and this is one of the official sample point accepted by many port states as "Representative sampling spot". Some of the port states like USCG also recommends sampling to be made on the engine return line to prove that the engine is free from any HSFO or residues.
Error: If the sampling is not done on these recognised spot can pose improper sulphur values.
2. Sampling Point: Proper sampling methods to be adhered to, on the approved sampling point the fuel shall be adequately drained to remove the residues on the sampling line. Also, the amount drained shall be enough to drain the complete sampling line length X 5 times. The container used shall be a fresh one without any residue from previous sampling.
Error: if the sampling is not done in the correct spot without proper draining can be contaminated with residue from previous Fuel.
3. Tank samples: Samples taken from the tank using a drain valve or inappropriate sampling spot can always pose improper reading and this shall not he considered as the "representative of fuel being used".
Error: Drain line which are aimed at draining water and contaminants drain the oil or water mixture where the sulphur is dissolved and always posed higher sulphur content. Do not use the tank drains as sample points.
Write a statement, stating what are the possibilities of in-correct changeover process or incorrect sampling process.
Letter of statement
DD/MM/YYYY
From
2nd Engineer
MV xyz
To
The port state control officer
PSC office
Re: Appeal to re-evaluate the sampling procedure
Sir,
Please accept this letter as our appeal contrary to Port state officers' decision as our vessel has used non-compliant fuel post the sampling done in the port of PQR on DD/MM/YY On behalf of our vessel, we Would like to bring your kind attention that, according to our shipboard SMS manual the sampling procedure carried out is not in compliance to our official procedure due to the following reasons:
1. The sampling point used to collect the sample was from the drain cock of our fuel heater. Designated official sampling point on our vessel is the sampling line attached to the vent line of fuel inlet filter attached to the engine and Sampling cock #2 fitted on the return line from the engine purge cock of fuel inlet filter to the main engine.
2. The fuel heater at the time of sampling was completely by-passed, Inlet & outlet valves were locked out and tagged out The heater may have contained the residue of HSFO which was used prior to entering the SECA zone. Lockout / tag out forms duly filled and signed during isolation of the heater valves is attached with this letter for your kind perusal. We, kindly ask you to consider above facts and would like to request you to revisit our ship to verify our procedures and for a resampling to ascertain the correct quality of fuel.
Prevention measures
We also would like to enlighten you about the preventive measures taken and applied to avoid reoccurrence of such issues, the following procedure is amended.
1. Identification labels have been applied to the representative sampling points properly to ensure the fuel sampling is taken at the designated spots.
2. Drain any ancillary equipment that is not in service during LSFO operation or adequately flush with LSFO prior to shutting down or by-passed.
3. Approved fuel system, Fuel change over process and the complete drawing layout in the engine room indicating designated sampling points have been posted near engines and fuel skids.
Thank you
Regards,
2nd Engineer
MV xyz
Answer : Possibilities of in correct change over process
(a) Changing over front HSFO to LSFO shall be done In accordance to ship board SMS procedure.
(b) The time to commence the C/O process purely dependent on the load on the engines and the consumption rate. If the engines (Main & Auxiliary) are running at full load hence the consumption is higher, it takes lesser time for the LSFO to be in the system and flushed completely.
1. The time given for the changeover process was too small and the residue of HSFO persisted in the system.
2. The mixing column OR buffer tank return line shall be changed over LSFO tank only after the changeover process is completed and LSFO is seen on the eight glass or through test cock. If the return is changed over inappropriately the LSFO tank gets contaminated with HSFO from the system.
3. All standby engines shall be started in order to be flushed with LSFO and to remove HSFO from their system completely. If standby engines are not started during C/O process the residual fuel when mixed with the LSFO will have, higher sulphur levels in the sampling.
4. The fuel skid (Fuel preparation circuit) containing filters, feed pump, automatic filters, heater, viscotherm, Flowmeter shall be thoroughly flushed with LSFO, Here the main contamination spot is the standby pumps which are usually not run during C/O process will contaminate the system.
5. Fuel transfer system if uses the same line and pumping arrangement, then the system shall be flushed adequately with LSFO to ensure they are free from any HSFO residues! If not flushed adequately there are chances for the LSFO tanks to be contaminated.
Possibilities incorrect sampling process
1.Representative sampling point Proper sampling point would be the fuel inlet to the engine and this is one of the official sample point accepted by many port states as "Representative sampling spot". Some of the port states like USCG also recommends sampling to be made on the engine return line to prove that the engine is free from any HSFO or residues.
Error: If the sampling is not done on these recognised spot can pose improper sulphur values.
2. Sampling Point: Proper sampling methods to be adhered to, on the approved sampling point the fuel shall be adequately drained to remove the residues on the sampling line. Also, the amount drained shall be enough to drain the complete sampling line length X 5 times. The container used shall be a fresh one without any residue from previous sampling.
Error: if the sampling is not done in the correct spot without proper draining can be contaminated with residue from previous Fuel.
3. Tank samples: Samples taken from the tank using a drain valve or inappropriate sampling spot can always pose improper reading and this shall not he considered as the "representative of fuel being used".
Error: Drain line which are aimed at draining water and contaminants drain the oil or water mixture where the sulphur is dissolved and always posed higher sulphur content. Do not use the tank drains as sample points.
Write a statement, stating what are the possibilities of in-correct changeover process or incorrect sampling process.
Letter of statement
DD/MM/YYYY
From
2nd Engineer
MV xyz
To
The port state control officer
PSC office
Re: Appeal to re-evaluate the sampling procedure
Sir,
Please accept this letter as our appeal contrary to Port state officers' decision as our vessel has used non-compliant fuel post the sampling done in the port of PQR on DD/MM/YY On behalf of our vessel, we Would like to bring your kind attention that, according to our shipboard SMS manual the sampling procedure carried out is not in compliance to our official procedure due to the following reasons:
1. The sampling point used to collect the sample was from the drain cock of our fuel heater. Designated official sampling point on our vessel is the sampling line attached to the vent line of fuel inlet filter attached to the engine and Sampling cock #2 fitted on the return line from the engine purge cock of fuel inlet filter to the main engine.
2. The fuel heater at the time of sampling was completely by-passed, Inlet & outlet valves were locked out and tagged out The heater may have contained the residue of HSFO which was used prior to entering the SECA zone. Lockout / tag out forms duly filled and signed during isolation of the heater valves is attached with this letter for your kind perusal. We, kindly ask you to consider above facts and would like to request you to revisit our ship to verify our procedures and for a resampling to ascertain the correct quality of fuel.
Prevention measures
We also would like to enlighten you about the preventive measures taken and applied to avoid reoccurrence of such issues, the following procedure is amended.
1. Identification labels have been applied to the representative sampling points properly to ensure the fuel sampling is taken at the designated spots.
2. Drain any ancillary equipment that is not in service during LSFO operation or adequately flush with LSFO prior to shutting down or by-passed.
3. Approved fuel system, Fuel change over process and the complete drawing layout in the engine room indicating designated sampling points have been posted near engines and fuel skids.
Thank you
Regards,
2nd Engineer
MV xyz
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