U.S. Coast Guard Safety Alerts (2)
Inspection of Fuel Oil Quick-Closing Valves & Electronically-Controlled Cargo Pump Engine Components
•INSPECTION OF FUEL OIL QUICK-CLOSING VALVES
The U.S. Coast Guard strongly recommends that owners and/or operators, vessel engineers, marine inspection personnel and others involved with the technical examination of machinery space equipment fully understand the critical nature and importance of fuel oil quick-closing valves (FOQCVs) and associated systems. FOQCV systems must be well maintained and tested in the same way they would be used in an emergency (e.g. close all valves on each system at the same time). Crewmember knowledge, testing, maintenance and repair, system operation and limitations, documentation, and spare parts are essential elements to review during an effective evaluation of an FOQCV system.
During a fire onboard the USNS SHUGHART on March 5, 2004, more than half of the FOQCVs failed to close properly, which prevented the ship's service generators from being secured. The investigators found that the valves had not been well maintained and the testing protocol used onboard the ship did not test the valves properly. During testing, valves were closed using a hydraulic hand pump system; the quantity of oil within the system should be sufficient to close all of them. However, there is no way to determine that the system contains enough oil to close all the valves, if prior to completing the testing some of the valves are reset!
International and domestic regulations require that positive shutoff valves located outside the fuel tank be arranged with a means to be closed remotely from outside the compartment. These positive shutoff valves may be valves that are remotely closed gradually (e.g. turning a mechanical reach rod) or power operated.
FOQCVs are positive shutoff valves and they may be the final means of securing the fuel to a flammable liquid fire. It is absolutely critical that the ability to close the valves be maintained at all times. The periodic maintenance necessary to ensure proper operation of the FOQCVs must be given the highest priority, and completed as required. Records of completed maintenance and testing should be kept on board the vessel.
Because FOQCVs and other positive shutoff valves on fuel tanks have the potential to prevent loss of life and/or critical equipment during a fire, the importance of verifying their proper operation can not be overstated. As a result of the USNS SHUGHART casualty, the U.S. Coast Guard Office of Systems Engineering developed recommended inspection procedures for the testing and operation of FOQCVs which follow. The U.S. Coast Guard strongly recommends that owners and/or operators, vessel engineers, marine inspection personnel and others ensure:
a) The valve operating system is capable of remotely closing all valves in the event of a fire. It is imperative the system is tested as designed. It may be designed to close valves sequentially or simultaneously. Also, there may be manual input such as a hydraulic hand pump operation required at the remote control station. There is no defined time limit to close the valve; the time required will depend on the size of the valve and the system design.
b) There should be technical manuals on board containing diagrams and information that describe the system components, recommended spare parts requirements, maintenance and operation. Schematics and drawings of the systems should also be available.
c) All machinery space workers should be able to identify the valves and how to close them locally and remotely in an emergency. They should be able to demonstrate substantial knowledge of the system, its importance and operation. Ship engineers should be familiar with the technical manual and the associated maintenance requirements for all of the system components.
During Coast Guard inspections, engineers should be able to explain to the marine inspector the important aspects of the manual, as well as the general maintenance requirements of the system and provide information as to when it was last performed. Further, they should be able to explain how the valves are reset following closure. A good test of a crew member's general knowledge of fire fighting would be to ask them details of the technical items noted above with an emphasis on why these valves are important.
The domestic regulations enforced by the U.S. Coast Guard for positive shutoff valves are contained in 46 CFR Part 56.50-60(d), Subparagraph 3. These regulations are available through the U.S. Government Printing Office (GPO) and may be downloaded without cost from the GPO's internet website http://www.gpoaccess.gov/index.html.
This safety alert is provided for informational purposes only and does not relieve any domestic or international safety, operational or material requirement. Developed by the Office of Domestic Vessel Activities (CG-5431), United States Coast Guard Headquarters, Washington, DC.
•ELECTRONICALLY-CONTROLLED CARGO PUMP ENGINE COMPONENTS
For many years, cargo pump engines on weather decks of Subchapter D & O tank barges had mechanical-type start and control systems. The installation of electronically controlled engines on tank barges since the 1990s has introduced non-approved electrical equipment associated with engine monitoring and control systems into hazardous locations (Class I, Division I) on thousands of tank barges nationwide.
U.S. Coast Guard District Eight recognized this problem with John Deere manufactured engines and distributed enforcement guidance to their field units on November 22, 2005. Since then, John Deere has engineered retrofit packages for approximately 400 units and has gained approval from the U.S. Coast Guard Marine Safety Center for some engine models. Because of widespread use of electronically controlled engines, we suspect there may be other equipment currently in use that similarly is not designed or approved for hazardous locations. Other manufacturers of these engines will likely need to follow suit with their own retrofit packages.
46 CFR 111.105-31(1) defines Class I / Division 1 locations as any area located within 10 feet (3 meters) of a cargo tank vent outlet or ullage opening, or cargo pipe flange or valve on a tank barge that carries a flammable or combustible cargo with a flashpoint below 60 degrees C (140 degrees F). By regulations, electrical equipment located in hazardous locations must be approved intrinsically safe, explosion-proof, or purged and pressurized.
On John Deere electronically controlled cargo pump engines, electrical ignition sources were found in control panels, notification lights, alternators, batteries, computers, and associated wiring for engine sensors. Since new components are still being designed and tested, it may be some time before all electronic components on John Deere engines can be re-engineered and retrofitted for hazardous locations. Again, we suspect other makes of electronically controlled engines have the same issues.
Until complete retrofit packages are designed and approved for these engines, vessel operators and OCMIs should take immediate steps to eliminate the risk by ensuring all electrical components on tank barges are in sound and serviceable condition, and those components that that are not suitable for hazardous locations are replaced as soon as possible.
See the photographs below for examples of electrical components on electronically-controlled pump engines that should be examined, repaired or replaced. All electric starters should be removed and replaced with a hydraulic starter with a manual hand pump, or a pneumatic starter with the air compressor located in a non-hazardous location.
This safety alert is provided for informational purposes only and does not relieve any domestic or international safety, operational or material requirement. Developed by the Office of Domestic Vessel Activities (CG-5431), United States Coast Guard Headquarters, Washington, DC. Questions should be directed to LT James T. Fogle at (202) 372-1038 or email@example.com .