Impact of EU Directive 2005/33/EC on Steam Propelled

LNG Ships

Introduction.

This document addresses issues raised by the requirements of the EU Directive

2005/33/EC due to come into force on 1 January 2010. The vessels subject to this
discussion are LNG ships with steam propulsion systems. It is recognised by SIGTTO
that there are similar, but not identical, concerns for, for instance, oil tankers with steam
driven cargo pumping installations. Others, notably, OCIMF and INTERTANKO are
addressing issues in that area. We have exchanged views with these organisations and
the views here do not contradict their position, but they are not quite the same, hence it is
appropriate to consider the impacts separately.

The issues around supply of fuels to meet the standards are not addressed in this
document, such issues affect all shipping, not just steam propelled LNG ships.

LNG Fleet Statistics

As of the end of April 2009, 313 LNG ships were in service of which 262 are steam
propelled. (32 are slow speed diesel with reliquefaction plants and 19 are dual fuel diesel
electric).

The order book currently stands at 77. Exact details of the propulsion type are difficult to
ascertain, but it is understood that some 25 - 30 % are steam ships.

Technology overview

The subject vessels are driven by steam propulsion systems typically consisting of two
boilers rated at about 60 bar and 510 °C providing steam to the main propulsion turbine
plant and auxiliaries. The boilers are designed for ‘dual firing’ and can burn either heavy
fuel oil (HFO) or gas derived from the cargo boil-off (generally referred to as boil-off gas
or BOG) or mixtures of the two. The HFO systems were designed typically with a turn
down ratio of 15:1, i.e. at full power a representative LNG vessel would, on HFO only,
consume about 150 t/day, the minimum load level on the boilers to maintain stable
combustion was about one fifteenth, i.e. consuming 10 t/day. Therefore, as built, dual
firing could only be maintained above this load. (Note: by manipulating number of
burners in operation, some vessels may be able to reduce this minimum fuel figure
significantly. Figures as low as 1.7 t/day per boiler have been achieved.)

Technically, many of these vessels can operate the boilers on 100 % gas, providing the
burner management system and associated equipment is appropriately designed and
demonstrated. (Note there may be commercial implications resulting from the wording
of the Sales and Purchase Agreements – ‘SPA’ - for the cargo.)

These ships were designed with the strictly limited ability to use distillate diesel fuel
(typically marine gas oil or MGO) for flashing from cold, which, under normal
circumstances only occurs at the end of refit period. However, the ‘best practice’ use
was limited to firing the first boiler up to a pressure of about 15 bar whereupon the fuel
oil heater system could be started up and the firing changed over to HFO.

The majority of LNG ships built in the last ten years employ boilers and burner
management systems to the designs of either Mitsubishi Heavy Industries (MHI) or
Kawasaki Heavy Industries (KHI). About ten years ago there were 100 LNG ships in
service, some having been constructed in the late 1960’s early 1970’s. Most of these
older vessels are still trading. The boilers and burner management systems on these
vessels may be to the design of manufacturers who are no longer in business, or, if they
are, they can no longer offer technical support.

Application of EU Directive to Steam LNG Vessels

As can be seen from the foregoing, the EU directive to burn fuels with a sulphur content
of 0.1% or less while in port raises certain considerable challenges for steam powered
LNG vessels.

Fundamentally there are two fuels that can be considered – distillate diesel fuels, e.g.
MGO as per explicit requirements of the EU Directive, or BOG. (Note BOG contains
zero sulphur compounds and its use will reduce CO2 emissions.)

In addition, consideration may be given for an approach that would combine burning
BOG with low sulphur heavy fuel oil. Low sulphur heavy fuel oil (meeting IMO SECA
requirements) currently has a sulphur content of less than 1.5% and this will fall to less
than 1.0% after June 2010. This combined fuel approach has the potential to achieve the
intended emission goal of the EU and could be considered under the equivalency clause
of Article 4c paragraph 4 of the Directive

A brief description of each of these approaches (MGO, 100% BOG, Equivalence – BOG
plus another fuel and exhaust gas Scrubbers) is provided.

Use of Distillate Diesel Fuels - Key Safety Issues

Fundamentally, burning distillate diesel fuels, in boilers is not inherently unsafe, what is
potentially unsafe is burning such fuels in boiler liquid fuel systems designed for burning
HFO.
The principal hazard arises from situations where unburnt fuel is admitted to a hot
furnace, typically following flame failure. The fuel vaporises forming a flammable cloud
which finds a source of ignition, possibly a burner ignitor or glowing residue (soot
particles) from the fuel. This results in a violent explosion in the gas side of the boiler.
There have been incidents which have lead to catastrophic failure of the boiler structure
and fatalities.

To prevent this happening, the prime function of the burner management system (BMS)
is to prevent conditions arising where fuel is admitted to the furnace when no flame is
present. Therefore, if loss of flame is detected, all fuel flow to the furnace is shut off
immediately. Following flame failure, the forced draft fans are set to purge the furnaces
of any vaporised fuel. (Note, whilst on many older vessels this function was automatic,
some Classification Society rules now require that this post failure purge is manually
initiated.)

When relighting, the BMS carefully monitors the furnace and, if no flame is detected
within a specific time of starting the ignition process, the fuel is shut off and the furnace
re-purged. This ‘trial for ignition’ time is arrived at from a calculation as to the tolerable
limit of vaporised fuel in the furnace and is a function of the flow characteristics of the
burner and an assessment of how much of the fuel vaporises and how quickly (for HFO
this may be less than 100 % whereas substantially all MGO will vaporise quickly in a hot
furnace).

From the foregoing, it is clear that vaporisation behaviour is important. To facilitate

atomisation and efficient combustion, HFO is typically pre-heated to 135 – 150 °C prior
to admission to the burner. This is necessary to facilitate atomisation and efficient
combustion. If MGO is heated to these figures, apart from having the undesirable effect
that vaporisation in event of flame failure is much quicker, it may form vapour pockets in
the fuel system leading to flame instability, which, in turn, may lead to flame failure and
boiler trip.

It should also be noted that some designs of burner equipment may lead to undesirable
heating of the MGO by atomising steam.

The settings of the time functions in the BMS and the vaporising behaviour, are the main
reasons why burning MGO in systems set up for HFO is potentially unsafe.

Possible Technical Solutions

It is only possible to give a high-level overview of the necessary studies and changes,
since each individual ship and its installation will need checking. The following
summarises:

• The BMS settings will need reviewing to ensure compatibility. It may or may not
be possible to arrive with settings suitable both for HFO and MGO.
 • A separate liquid fuel supply system to the burner front for MGO will be needed
to ensure a supply of ambient temperature MGO to the burners.

• The burner equipment will need assessing. Some types of burner construction are
unsuitable for use with a combination of MGO and steam atomising.

• The operating procedures to ensure safe change over from one fuel type to
another and the procedure to follow following a total flame failure would need to
be investigated.

• Provision of adequate storage capacity of MGO. This will need checking on each
ship.

Any modifications identified would need to be submitted to the ship’s Classification

Society and, possibly, to the Flag State Administration for approval before it can be
implemented.

Use of 100% BOG

It is noted above that technically it should be possible to burn 100% BOG whilst
alongside. To implement this each specific ship would need to be studied to ensure that:

(a) the BMS and combustion control systems are designed for this operation,
(b) the flame detection equipment is suitable for 100 % gas operation at low loads
(c) there are no adverse interactions with the cargo transfer ESD system.

Whilst burning 100 % BOG during relatively stable state operation, particularly at high
load, is undemanding, there are uncertainties around such operations when manoeuvring
the ship on entering and leaving port which can result in large and rapid load changes.
Also, when under very low load, which may be experienced alongside, stable combustion
may be difficult to achieve. The ability of the combustion control system to meet these
demands on gas only will need checking on each ship.

100% BOG operation does not provide the complete solution because it does not cover
the case for relighting after flame failure when alongside (the IGC Code requires the gas
fuel to be ignited from an oil fuel burner). Additionally, there may be circumstances
where gas is not available, e.g . ships entering and leaving refit/dry dock within the EU.
Therefore 100% BOG use on its own cannot provide a full solution to comply with the
EU Directive for all circumstances.

(Note that LNGC vessels enter refit typically every 2.5 years, although some more
modern vessels only enter refit once every 5 years.)
Exhaust Gas Scrubbing

An alternative technology is that of post combustion scrubbing. Whilst much work is

being done on developing designs, there are still uncertainties around this technology.
Critical technical issues identified are:

• The treatment and disposal of the removed sulphur compounds.

• Additional back pressure on the flue gas path created by the scrubbing unit may
result in the need to redesign the forced draft fan system and ducting.
• The need for substantial structural alterations to the boiler casing and funnel to
accommodate the additional equipment.

These technical issues, together with the costs for installation, which are expected to be
much higher than the other options discussed in this paper, and the lead time to fabricate
and install render it unlikely that, in the time scale of the EU fuels directive, this
technology will play a significant part.

Equivalence - Burning BOG with Low Sulphur Heavy Fuel Oil

As noted in the “Technology Overview”, LNG ships are currently designed to burn a
combination of BOG and heavy fuel oil. Today, in SECA areas, the heavy fuel used is
low sulphur heavy fuel oil, which can be safely handled. When manoeuvring or in port,
the boiler operates in dual fuel mode, using a pilot flame of heavy fuel oil and BOG. If
there is an interruption of BOG for any reason, the combustion control system
immediately increases the heavy fuel supply so that the boiler firing rate is maintained.
This is often referred to as the ‘fuel boost’ function.

This solution has the advantage of using the existing systems as designed with minimal
modification. Some adjustment to the BMS and combustion control settings may be
needed to accommodate the low boiler loads experienced while in port. Calculations can
then be done to demonstrate that the sulphur emissions with the combined fuels is equal
to, or less than, burning MGO over the same port stay – this due to the fact that the heavy
fuel oil is used only as a pilot fuel and BOG makes up the main fuel source. A variation
on this would be to run one boiler on 100% gas and one on dual fuel.

Compared with burning MGO, or dual firing MGO with BOG, this solution requires
minimum modification enabling rapid implementation.

Boiler light-off, in the case of a trip is on low sulphur heavy fuel oil, but it should be
noted that, this is an unusual occurrence and most port stays will pass without having a
boiler trip. Furthermore, even if such an event should occur, the total sulphur emissions
throughout that particular port stay are less than burning MGO over that same period.

This solution is similar to the 100% BOG case in that it does not address the dry dock
scenario. Additionally, the equipment on older LNG ships may not be able to comply
with the low pilot fuel flow rates required without substantial modification to their
combustion control systems and BMS.

Related issues

Whilst the intent of this document is to address the requirements of the EU Directive
2005/33/EC, any discussion would be incomplete without some reference to interaction
with MARPOL Annex VI and Sulphur Emissions Control Area (SECA) requirements (to
become Emission Control Areas or ECA’s). Current SECA requirements are for a fuel
with sulphur content of less than 1.5 %, coming down to 1.0 % in July 2010. In 2015, the
required content is reduced to that of the EU fuel Directive. At first study, these
requirements may result in the need of a ship to carry 3 grades of liquid fuel for the
interim period to 2015, HFO for deep sea, low sulphur fuel oil for SECA and MGO for
in-port use to meet the EU Directive. The ability of a ship to receive, store separately and
use each fuel type will need checking.

Cost Estimates
It is very difficult in a general paper like this to give realistic cost estimates. In preparing
this paper, figures ranging from USD 100 000 to USD 2 000 000 have been cited with a
median of about USD 800 000 to USD 1 000 000 for full compliance with the Directive
requirements, i.e. modification to provide safe and practical firing of the main boilers on
distillate diesel fuels. The lowest figure is probably not credible. The USD 2 000 000
figure comes from one of the manufacturers of the main boilers commonly used in LNG
ships, but it is not clear to what extent one-off engineering design costs are included in
that figure.

For the 100 % BOG route, no cost estimates are available. The results depend greatly on
the extent of modification required. Modification to provide a similar level of control
performance to that on HFO in terms of turn down and speed of response may require
substantial re-engineering of the fuel gas system and therefore may come out at a higher
cost than compliance as above.

For the ‘equivalency’ route, implementation costs are expected to be lower. If the
argument for this route is based on compliance with paragraphs 4 c, then installation of
continuous uptake flue gas monitoring equipment is mandated. Costs for this are in the
order of magnitude of USD 100 000.

No estimates for the costs associated with the installation of exhaust gas scrubbing
equipment are made here.

All these figures should be treated with caution since each ship will need individual
studies to secure a safe solution.
Note: These costs estimates do not include any costs for off-hire time for the vessel and
for the associated costs of taking an LNG vessel out of service, e.g. inerting, gassing up
and cool-down costs.

Conclusions

Modification of LNG ships boiler systems to run safely on distillate diesel fuels in
compliance with EU Directive 2005/33/EC presents challenges. Whilst much work is
being done, in the time scale available, modification of all the fleet is not possible.

Operation with 100 % BOG fuel will satisfy both the requirements of the EU Directive
and of MARPOL and may be seen as a longer term aspiration. This approach eliminates
sulphur from the combustion process and reduces CO2 emissions for a given power
demand. Whilst 100 % gas burning has substantial environmental advantages, it cannot
alone provide a complete solution to the issue for existing LNG ships since it cannot
cover the case for ships going to and leaving refit yards within the EU and it cannot,
under the current IGC Code, cover the case of boiler relight after flame failure or trip.
The use of a combination of BOG and HFO pilot fuel has similar restrictions. Unless
there is some derogation or waiver, the only complete solution will have to address the
safe use of MGO in LNG ship.

Whichever solution selected will necessitate ship-specific studies to identify the solution
for each ship. The results of such studies will need approval by Classification Society
and Flag State before implementation.
 SUMMARY TABLE OF SOLUTIONS

Item Fuel Description Advantages Disadvantages

1 MGO + Fully meets the EU − Introduces a new
Directive. operating risk
− Requires piping and
BMS modification
− May require boiler front
and/or bunker tank
modification
− Slow to implement
2 100% BOG + Better than EU target − Does not meet EU rule
when burning 100% in the limited cases
BOG when re-lighting boiler
+ Reduced GHG and when vessel dry
emissions docks at an EU
+ Relatively quick to shipyard
implement, but − Needs testing and
probably only on possible modification to
newer vessels BMS and gas
management systems
− Possible adverse
interaction with ESD
systems
− Needs Flag State
Approval under IGC
code.
3 Dual Fuel + Meets EU emission − Does not meet EU rule
target as equivalent in the limited cases
solution when re-lighting boiler
+ Reduced GHG and when vessel dry
emissions. docks at an EU
+ Ready to implement, shipyard
but probably restricted − Needs EU Approval as
to newer vessels equivalent solution.
4 Scrubbers + May meet EU − Requires substantial
emission target as an modification work to
equivalent solution implement
− Slow to implement
− Not proven for this
application
− Requires handling of
sulphur waste/sludge