Guidelines superseded by resolution MEPC.340(77)
RESOLUTION
MEPC.259(68)/Corr.2
(adopted on 15 May 2015)
2015 GUIDELINES FOR EXHAUST GAS CLEANING SYSTEMS
THE MARINE ENVIRONMENT
PROTECTION COMMITTEE,
RECALLING Article 38(a) of
the Convention on the International Maritime Organization concerning the
functions of the Marine Environment Protection Committee (the Committee)
conferred upon it by international conventions for the prevention and control
of marine pollution from ships,
RECALLING ALSO that, at its
fifty-eighth session, the Committee adopted, by resolution MEPC.176(58), a
revised MARPOL Annex VI which significantly strengthens the emission limits for
sulphur oxides (SOX),
RECALLING FURTHER that, at
its fifty-ninth session, the Committee adopted, by resolution MEPC.184(59),
the 2009 Guidelines for exhaust gas cleaning systems (hereinafter
referred to as "2009 EGCS Guidelines"),
NOTING that the revised
MARPOL Annex VI entered into force on 1 July 2010,
NOTING ALSO that regulation
4 of MARPOL Annex VI allows the use of an alternative compliance method at
least as effective in terms of emission reductions as that required by MARPOL
Annex VI, including any of the standards set forth in regulation 14, taking
into account guidelines developed by the Organization,
RECOGNIZING the need to
update the 2009 EGCS Guidelines accordingly,
HAVING CONSIDERED, at its
sixty-eighth session, draft amendments to the 2009 EGCS Guidelines, prepared by
the Sub-Committee on Pollution Prevention and Response, at its second session,
1 ADOPTS the 2015 Guidelines for exhaust gas cleaning
systems, as set out in the annex to the present resolution;
2 INVITES
Administrations to take these Guidelines into account when allowing the use of
an exhaust gas cleaning system in accordance with regulation 4 of MARPOL Annex
VI;
3 REQUESTS
Parties to MARPOL Annex VI and other Member Governments to bring these
Guidelines to the attention of shipowners, ship operators, shipbuilders, marine
diesel engine manufacturers and any other interested groups;
4 INVITES
Administrations to provide for collection of data as described in appendix 3 of
these Guidelines;
5 AGREES
to keep these Guidelines under review in the light of experience gained with
their application;
6 SUPERSEDES
the 2009 EGCS Guidelines adopted by resolution MEPC.184(59).
ANNEX
2015 GUIDELINES FOR EXHAUST GAS CLEANING SYSTEMS
1 INTRODUCTION
1.1 Regulation
14 of Annex VI requires ships to use fuel oil with a sulphur content not
exceeding that stipulated in regulations 14.1 or 14.4. Regulation 4 allows,
with the approval of the Administration, the use of an alternative compliance
method at least as effective in terms of emission reductions as that required
by the Annex, including the standards set forth in regulation 14. The
Administration of a Party should take into account any relevant guidelines
developed by the Organization pertaining to alternatives provided for in
regulation 4.
1.2 Similar
to a NOX emission reduction system, an exhaust gas cleaning (EGC)
unit may be approved subject to periodic parameter and emission checks or the
system may be equipped with a continuous emission monitoring system. These
guidelines have been developed with the intention of being objective and
performance oriented. Furthermore, use of the SO2(ppm)/CO2(%)
ratio method will simplify the monitoring of SOX emission and
facilitate approval of an EGC unit. See appendix 2 for the rationale explaining
the use of SO2(ppm)/CO2(%) as the basis for system
monitoring.
1.3 Compliance
should be demonstrated on the basis of the SO2(ppm)/CO2(%
v/v) ratio values.
Table 1: Fuel oil sulphur limits recorded in regulations 14.1 and
14.4 and corresponding emissions values
|
Fuel oil sulphur content
(% m/m) |
Ratio emission SO2(ppm)/CO2(%
v/v) |
|
4.50 |
195.0 |
|
3.50 |
151.7 |
|
1.50 |
65.0 |
|
1.00 |
43.3 |
|
0.50 |
21.7 |
|
0.10 |
4.3 |
Note:
The use of the ratio emissions limits is only applicable when using petroleum
based distillate or residual fuel oils. See appendix 2 for application of the
ratio method.
1.4 These guidelines
are recommendatory in nature, however, Administrations are invited to base the
implementation of the relevant requirements of regulation 4 of MARPOL Annex VI
on them.
2 GENERAL
2.1 Purpose
2.1.1 The
purpose of these guidelines is to specify the requirements for the testing,
survey certification and verification of EGC systems under regulation 4 of
MARPOL Annex VI to ensure that they provide effective equivalence to the
requirements of regulations 14.1 and 14.4 of MARPOL Annex VI.
2.1.2 These
guidelines permit two schemes: Scheme A (unit certification with parameter and
emission checks and Scheme B (continuous emission monitoring with parameter
checks).
2.1.3 For
ships which are to use an exhaust gas cleaning system in part or in total in
order to comply with regulations 14.1 and/or 14.4 of MARPOL Annex VI, there
should be an approved SOX Emissions Compliance Plan (SECP).
2.2 Application
2.2.1 These
guidelines apply to any EGC unit as fitted to fuel oil combustion machinery,
excluding shipboard incinerators, installed on board a ship.
2.3 Definitions and
required documents
|
Fuel oil combustion unit |
Any engine, boiler, gas
turbine, or other fuel oil fired equipment, excluding shipboard incinerators |
|
EGC |
Exhaust gas cleaning |
|
SOX |
Sulphur oxides |
|
SO2 |
Sulphur dioxide |
|
CO2 |
Carbon dioxide |
|
UTC |
Universal Time Co-ordinated |
|
Certified Value |
The SO2/CO2
ratio specified by the manufacturer that the EGC unit is certified
as meeting when operating on a continuous basis on the manufacturers
specified maximum fuel sulphur content |
|
In situ |
Sampling directly within an exhaust gas stream |
|
MCR |
Maximum Continuous Rating |
|
Load range |
Maximum rated power of
diesel engine or maximum steaming rate of the boiler |
|
SECP |
SOX Emissions Compliance Plan |
|
SECC |
SOX Emissions Compliance Certificate |
|
ETM-A |
EGC system – Technical Manual for Scheme A |
|
ETM-B |
EGC system – Technical Manual for Scheme B |
|
OMM |
Onboard Monitoring Manual |
|
EGC Record Book |
A record of the EGC unit
in-service operating parameters, component adjustments, maintenance and
service records as appropriate |
|
Document |
Scheme A |
Scheme B |
|
SECP |
X |
X |
|
SECC |
X |
|
|
ETM Scheme A |
X |
|
|
ETM Scheme B |
|
X |
|
OMM |
X |
X |
|
EGC Record Book or Electronic Logging System |
X |
X |
3 SAFETY NOTE
Due attention is to be given
to the safety implications related to the handling and proximity of exhaust
gases, the measurement equipment and the storage and use of pressurized
containers of pure and calibration gases. Sampling positions and permanent
access platforms should be such that this monitoring may be performed safely.
In locating discharge outlet of washwater used in the EGC unit, due
consideration should be given to the location of the ship's seawater inlet. In
all operating conditions the pH should be maintained at a level that avoids
damage to the vessel’s anti-fouling system, the propeller, rudder and other
components that may be vulnerable to acidic discharges, potentially causing
accelerated corrosion of critical metal components.
4 SCHEME A – EGC
SYSTEM APPROVAL, SURVEY AND CERTIFICATION USING PARAMETER AND EMISSION CHECKS
4.1 Approval of EGC
systems
4.1.1
General
Options under Scheme A of these
guidelines provide for:
.1 unit approval;
.2 serially manufactured units; and
.3 production range approval.
4.1.2 Unit approval
4.1.2.1 An EGC unit should be certified as
capable of meeting the limit value, (the Certified Value), specified by the
manufacturer (e.g. the emission level the unit is capable of achieving on a
continuous basis) with fuel oils of the manufacturer’s specified maximum % m/m
sulphur content and for the range of operating parameters, as listed in
paragraph 4.2.2.1.2, for which they are to be approved. The Certified Value
should at least be suitable for ship operations under requirements given by
MARPOL Annex VI regulations 14.1 and/or 14.4.
4.1.2.2 Where testing is not to be
undertaken with fuel oils of the manufacturer's specified maximum % m/m sulphur
content, the use of two test fuels with a lower % m/m sulphur content is
permitted. The two fuels selected should have a difference in % m/m sulphur
content sufficient to demonstrate the operational behaviour of the EGC unit and
to demonstrate that the Certified Value can be met if the EGC unit were to be
operated with a fuel of the manufacturer's specified maximum % m/m sulphur
content. In such cases a minimum of two tests, in accordance with section 4.3
as appropriate, should be performed. These need not be sequential and could be
undertaken on two different, but identical, EGC units.
4.1.2.3 The maximum and, if applicable,
minimum exhaust gas mass flow rate of the unit should be stated. The effect of
variation of the other parameters defined in paragraph 4.2.2.1.2 should be
justified by the equipment manufacturer. The effect of variations in these
factors should be assessed by testing or otherwise as appropriate. No variation
in these factors, or combination of variations in these factors, should be such
that the emission value of the EGC unit would be in excess of the Certified
Value.
4.1.2.4 Data obtained in accordance with
this section should be submitted to the Administration for approval together
with the ETM-A.
4.1.3 Serially
manufactured units
In the case of nominally
similar EGC units of the same mass flow ratings as that certified under 4.1.2,
and to avoid the testing of each EGC unit, the equipment manufacturer may
submit, for acceptance by the Administration, a conformity of production
arrangement. The certification of each EGC unit under this arrangement should
be subject to such surveys that the Administration may consider necessary as to
assure that each EGC unit has an emission value of not more than the Certified
Value when operated in accordance with the parameters defined in paragraph
4.2.2.1.2.
4.1.4 Product range
approval
4.1.4.1 In the case of an EGC unit of the
same design, but of different maximum exhaust gas mass flow capacities, the
Administration may accept, in lieu of tests on an EGC unit of all capacities in
accordance with section 4.1.2, tests of EGC systems of three different capacities
provided that the three tests are performed at intervals including the highest,
lowest and one intermediate capacity rating within the range.
4.1.4.2 Where there are significant
differences in the design of EGC units of different capacities, this procedure
should not be applied unless it can be shown, to the satisfaction of the
Administration, that in practice those differences do not materially alter the
performance between the various EGC unit types.
4.1.4.3 For EGC units of different capacities,
the sensitivity to variations in the type of combustion machinery to which they
are fitted should be detailed together with sensitivity to the variations in
the parameters listed in paragraph 4.2.2.1.2. This should be on the basis of
testing, or other data as appropriate.
4.1.4.4 The effect of changes of EGC unit
capacity on washwater characteristics should be detailed.
4.1.4.5 All supporting data obtained in
accordance with this section, together with the ETM-A for each capacity unit,
should be submitted to the Administration for approval.
4.2 Survey and certification
4.2.1 Procedures for the
certification of an EGC unit
4.2.1.1 In order to meet the requirements of
section 4.1 either prior to, or after installation on board, each EGC unit
should be certified as meeting the Certified Value specified by the
manufacturer (e.g. the emission level the unit is capable of achieving on a
continuous basis) under the operating conditions and restrictions as given by
the EGC Technical Manual (ETM-A) as approved by the Administration.
4.2.1.2 Determination of the Certified Value
should be in accordance with the provisions of these guidelines.
4.2.1.3 Each EGC unit meeting the
requirements of paragraph 4.2.1.1 should be issued with a SECC by the
Administration. The form of the SECC is given in appendix 1.
4.2.1.4 Application for an SECC should be
made by the EGC system manufacturer, shipowner or other party.
4.2.1.5 Any subsequent EGC units of the same
design and rating as that certified under paragraph 4.2.1.1 may be issued with
an SECC by the Administration without the need for testing in accordance with
paragraph 4.2.1.1 subject to section 4.1.3 of these guidelines.
4.2.1.6 EGC units of the same design, but
with ratings different from that certified under paragraph 4.2.1.1 may be
accepted by the Administration subject to section 4.1.4 of these guidelines.
4.2.1.7 EGC units which treat only part of
the exhaust gas flow of the uptake in which they are fitted should be subject
to special consideration by the Administration to ensure that under all defined
operating conditions that the overall emission value of the exhaust gas
downstream of the system is no more than the Certified Value.
4.2.2 EGC System Technical
Manual "Scheme A" (ETM-A)
4.2.2.1 Each EGC unit should be supplied
with an ETM-A provided by the manufacturer. This ETM-A should, as a minimum,
contain the following information:
.1 the identification of the unit (manufacturer,
model/type, serial number and other details as necessary) including a
description of the unit and any required ancillary systems;
.2 the operating limits, or range of operating
values, for which the unit is certified. These should, as a minimum, include:
.1 maximum and, if applicable, minimum mass flow
rate of exhaust gas;
.2 the power, type and other relevant parameters
of the fuel oil combustion unit for which the EGC unit is to be fitted. In the
cases of boilers, the maximum air/fuel ratio at 100% load should also be given.
In the cases of diesel engines whether the engine is of 2 or 4-stroke cycle;
.3 maximum and minimum washwater flow rate,
inlet pressures and minimum inlet water alkalinity (ISO 9963-1-2);
.4 exhaust gas inlet temperature ranges and
maximum and minimum exhaust gas outlet temperature with the EGC unit in
operation;
.5 exhaust gas differential pressure range and
the maximum exhaust gas inlet pressure with the fuel oil combustion unit
operating at MCR or 80% of power rating whichever is appropriate;
.6 salinity levels or fresh water elements
necessary to provide adequate neutralizing agents; and
.7 other factors concerning the design and
operation of the EGC unit relevant to achieving a maximum emission value no
higher than the Certified Value;
.3 any requirements or restrictions applicable
to the EGC unit or associated equipment necessary to enable the unit to achieve
a maximum emission value no higher than the Certified Value;
.4 maintenance, service or adjustment
requirements in order that the EGC unit can continue to achieve a maximum
emission value no higher than the Certified Value. The maintenance, servicing
and adjustments should be recorded in the EGC Record Book;
.5 corrective actions in case of exceedances of
the applicable maximum allowable SO2/CO2 ratio, or wash water discharge
criteria;
.6 a verification procedure to be used at
surveys to ensure that its performance is maintained and that the unit is used
as required (see section 4.4);
.7 through range performance variation in washwater
characteristics;
.8 design requirements of the washwater system;
and
.9 the SECC.
4.2.2.2 The ETM-A should be approved by the
Administration.
4.2.2.3 The ETM-A should be retained on
board the ship onto which the EGC unit is fitted and should be available for
surveys as required.
4.2.2.4 Amendments to the ETM-A which
reflect EGC unit changes that affect performance with respect to emissions to
air and/or water should be approved by the Administration. Where additions,
deletions or amendments to the ETM-A are separate to the ETM-A as initially
approved, they should be retained with the ETM-A and should be considered as
part of it.
4.2.3 In-service surveys
4.2.3.1 The EGC unit should be subject to
survey on installation and at initial, annual/intermediate and renewals surveys
by the Administration.
4.2.3.2 In accordance with regulation 10 of
MARPOL Annex VI, EGC units may also be subject to inspection by port State
control.
4.2.3.3 Prior to use, each EGC unit should
be issued with an SECC by the Administration.
4.2.3.4 Following the installation survey as
required by paragraph 4.2.3.1, section 2.6 of the Supplement to the ship's
International Air Pollution Certificate should be duly completed.
4.3 Emission limits
4.3.1 Each EGC unit should be capable of reducing
emissions to equal to or less than the Certified Value at any load point when
operated in accordance with the criteria as given in paragraph 4.2.2.1.2, as
specified in paragraphs 4.3.2 to 4.3.5 of these guidelines, and as excepted in
paragraph 4.3.7.
4.3.2 EGC units fitted to main propulsion diesel
engines should meet the requirements of paragraph 4.3.1 at all loads between 25
to 100% of the load range of the engines to which they are fitted.
4.3.3 EGC units fitted to auxiliary diesel engines
should meet the requirements of paragraph 4.3.1 at all loads between 10 to 100%
of the load range of the engines to which they are fitted.
4.3.4 EGC units fitted to diesel engines which
supply power for both main propulsion and auxiliary purposes should meet the
requirements of paragraph 4.3.3.
4.3.5 EGC units fitted to
boilers should meet the requirements of paragraph 4.3.1 at all loads between 10
to 100% of the load range (steaming rates) or, if the turn down ratio is
smaller, over the actual load range of the boilers to which they are fitted.
4.3.6 In order to demonstrate performance, emission
measurements should be undertaken, with the agreement of the Administration, at
a minimum of four load points. One load point should be at 95 to 100% of the
maximum exhaust gas mass flow rate for which the unit is to be certified. One
load point should be within 5% of the minimum exhaust gas mass flow
rate for which the unit is to be certified. The other two load points should be
equally spaced between the maximum and minimum exhaust gas mass flow rates.
Where there are discontinuities in the operation of the system the number of
load points should be increased, with the agreement of the Administration, so
that it is demonstrated that the required performance over the stated exhaust
gas mass flow rate range is retained. Additional intermediate load points should
be tested if there is evidence of an emission peak below the maximum exhaust
gas mass flow rate and above, if applicable, the minimum exhaust gas flow rate.
These additional tests should be sufficient number as to establish the emission
peak value.
4.3.7 For loads below those specified in paragraphs
4.3.2 to 4.3.5, the EGC unit should continue in operation. In those cases where
the fuel oil combustion equipment may be required to operate under idling
conditions, the SO2 emission concentration (ppm) at standardized O2
concentration (15.0% diesel engines, 3.0% boilers) should not exceed 50 ppm.
4.4 Onboard procedures for demonstrating compliance
4.4.1 For each EGC unit, the ETM-A should contain a
verification procedure for use at surveys as required. This procedure should
not require specialized equipment or an in-depth knowledge of the system. Where
particular devices are required they should be provided and maintained as part
of the system. The EGC unit should be designed in such a way as to facilitate
inspection as required. The basis of this verification procedure is that if all
relevant components and operating values or settings are within those as
approved, then the performance of the EGC system is within that required
without the need for actual exhaust emission measurements. It is also necessary
to ensure that the EGC unit is fitted to a fuel oil combustion unit for which
it is rated – this forms part of the SECP. A Technical File related to an EIAPP
certificate, if available, or an Exhaust Gas Declaration issued by the engine
maker or designer or another competent party or a Flue Gas Declaration issued
by the boiler maker or designer or another competent party serves this purpose
to the satisfaction of the Administration.
4.4.2 Included in the verification procedure should
be all components and operating values or settings which may affect the
operation of the EGC unit and its ability to meet the Certified Value.
4.4.3 The verification procedure should be
submitted by the EGC system manufacturer and approved by the Administration.
4.4.4 The verification procedure should cover both
a documentation check and a physical check of the EGC unit.
4.4.5 The surveyor should verify that each EGC unit
is installed in accordance with the ETM-A and has an SECC as required.
4.4.6 At the discretion of the Administration, the
surveyor should have the option of checking one or all of the identified
components, operating values or settings. Where there is more than one EGC
unit, the Administration may, at its discretion, abbreviate or reduce the
extent of the survey on board, however, the entire survey should be completed
for at least one of each type of EGC unit on board provided that it is expected
that the other EGC units perform in the same manner.
4.4.7 The EGC unit should include means to
automatically record when the system is in use. This should automatically
record, at least at the frequency specified in paragraph 5.4.2, as a minimum,
washwater pressure and flow rate at the EGC unit's inlet connection, exhaust
gas pressure before and pressure drop across the EGC unit, fuel oil combustion
equipment load, and exhaust gas temperature before and after the EGC unit. The
data recording system should comply with the requirements of sections 7 and 8.
In case of a unit consuming chemicals at a known rate as documented in ETM-A,
records of such consumption in the EGC Record Book also serves this purpose.
4.4.8 Under Scheme A, if a continuous exhaust gas
monitoring system is not fitted, it is recommended that a daily spot check of
the exhaust gas quality in terms of SO2(ppm)/CO2(%)
ratio, is used to verify compliance in conjunction with parameter checks
stipulated in paragraph 4.4.7. If a continuous exhaust gas monitoring system is
fitted, only daily spot checks of the parameters listed in paragraph 4.4.7
would be needed to verify proper operation of the EGC unit.
4.4.9 If the EGC system manufacturer is unable to
provide assurance that the EGC unit will meet the Certified Value or below between
surveys, by means of the verification procedure stipulated in paragraph 4.4.1,
or if this requires specialist equipment or in-depth knowledge, it is
recommended that continuous exhaust gas monitoring of each EGC unit be used,
Scheme B, to assure compliance with regulations 14.1 and/or 14.4 of MARPOL
Annex VI.
4.4.10 An EGC Record Book should be maintained by the
shipowner recording maintenance and service of the unit including like-for-like
replacement. The form of this record should be submitted by the EGC system
manufacturer and approved by the Administration. This EGC Record Book should be
available at surveys as required and may be read in conjunction with
engine-room log-books and other data as necessary to confirm the correction
operation of the EGC unit. Alternatively, this information should be recorded
in the vessel's planned maintenance record system as approved by the
Administration.
5 SCHEME B – EGC SYSTEM APPROVAL, SURVEY AND CERTIFICATION
USING CONTINUOUS MONITORING OF SOX EMISSIONS
5.1 General
This Scheme should be used
to demonstrate that the emissions from a fuel oil combustion unit fitted with
an EGC will, with that system in operation, result in the required emission
value (e.g. as stated in the SECP) or below at any load point, including during
transient operation and thus compliance with the requirements of regulations
14.1 and/or 14.4 of MARPOL Annex VI.
5.2 Approval
Compliance demonstrated in
service by continuous exhaust gas monitoring. Monitoring system should be
approved by the Administration and the results of that monitoring available to
the Administration as necessary to demonstrate compliance as required.
5.3 Survey and certification
5.3.1 The monitoring system of the EGC system
should be subject to survey on installation and at initial, annual/intermediate
and renewals surveys by the Administration.
5.3.2 In accordance with regulation 10 of MARPOL Annex VI, monitoring
systems of EGC units may also be subject to inspection by port State control.
5.3.3 In those instances where an EGC system is installed, section 2.6
of the Supplement to the ship's International Air Pollution Prevention
Certificate should be duly completed.
5.4 Calculation of emission rate
5.4.1 Exhaust gas composition in terms of SO2(ppm)/CO2(%)
should be measured at an appropriate position after the EGC unit and that
measurement should be in accordance with the requirements of section 6 as
applicable.
5.4.2 SO2(ppm) and CO2(%) to be continuously
monitored and recorded onto a data recording and processing device at a rate
which should not be less than 0.0035 Hz.
5.4.3 If more than one analyser is to be used to determine the SO2/CO2
ratio, these should be tuned to have similar sampling and measurement
times and the data outputs aligned so that the SO2/CO2
ratio is fully representative of the exhaust gas composition.
5.5 Onboard procedures for demonstrating compliance with emission
limit
5.5.1 The data recording system should comply with the requirements of
sections 7 and 8.
5.5.2 Daily spot checks of the parameters listed in paragraph 4.4.7 are
needed to verify proper operation of the EGC unit and should be recorded in the
EGC Record Book or in the engine-room logger system.
5.6 EGC System Technical Manual "Scheme B" (ETM-B)
5.6.1 Each EGC unit should be supplied with an ETM-B provided by the
manufacturer. This ETM-B should, as a minimum, contain the following
information:
.1 the identification of the unit (manufacturer,
model/type, serial number and other details as necessary) including a
description of the unit and any required ancillary systems;
.2 the operating limits, or range of operating
values, for which the unit is certified. These should, as a minimum, include:
.1 maximum and, if applicable, minimum mass flow
rate of exhaust gas;
.2 the power, type and other relevant parameters
of the fuel oil combustion unit for which the EGC unit is to be fitted. In the
cases of boilers, the maximum air/fuel ratio at 100% load should also be given.
In the cases of diesel engines whether the engine is of 2 or 4-stroke cycle;
.3 maximum and minimum washwater flow rate,
inlet pressures and minimum inlet water alkalinity (ISO 9963-1-2);
.4 exhaust gas inlet temperature ranges and
maximum and minimum exhaust gas outlet temperature with the EGC unit in
operation;
.5 exhaust gas differential pressure range and
the maximum exhaust gas inlet pressure with the fuel oil combustion unit
operating at MCR or 80% of power rating whichever is appropriate;
.6 salinity levels or fresh water elements
necessary to provide adequate neutralizing agents; and
.7 other parameters as necessary concerning the
operation of the EGC unit;
.3 any requirements or restrictions applicable
to the EGC unit or associated equipment;
.4 corrective actions in case of exceedances of
the applicable maximum allowable SO2/CO2 ratio, or
washwater discharge criteria;
.5 through range performance variation in
washwater characteristics;
.6 design requirements of the washwater system.
5.6.2 The ETM-B should be approved by the
Administration.
5.6.3 The ETM-B should be retained on board the
ship onto which the EGC unit is fitted. The ETM-B should be available for
surveys as required.
5.6.4 Amendments to the
ETM-B which reflect EGC unit changes that affect performance with respect to
emissions to air and/or water should be approved by the Administration. Where
additions, deletions or amendments to the ETM-B are separate to the ETM-B as
initially approved, they should be retained with the ETM-B and should be
considered as part of it.
6 EMISSION TESTING
6.1 Emission testing
should follow the requirements of the NOX Technical Code 2008,
chapter 5, and associated appendices, except as provided for in these
guidelines.
6.2 CO2
should be measured using an analyser operating on non-dispersive infrared
(NDIR) principle and with additional equipment such as dryers as necessary. SO2
should be measured using analysers operating on non-dispersive infrared (NDIR)
or non-dispersive ultra-violet (NDUV) principles and with additional equipment
such as dryers as necessary. Other systems or analyser principles may be
accepted, subject to the approval of the Administration, provided they yield
equivalent or better results to those of the equipment referenced above. For acceptance
of other CO2 systems or analyser principles, the reference method
should be in accordance with the requirements of appendix III of the NOX
Technical Code 2008.
6.3 Analyser
performance should be in accordance with the requirements of sections 1.6 to
1.10 of appendix III of the NOX Technical Code 2008.
6.4 An exhaust gas
sample for SO2 should be obtained from a representative sampling
point downstream of the EGC unit.
6.5 SO2 and
CO2 should be monitored using either in situ or extractive sample
systems.
6.6 Extractive exhaust
gas samples for SO2 determination should be maintained at a
sufficient temperature to avoid condensed water in the sampling system and
hence loss of SO2.
6.7 If an extractive
exhaust gas sample for determination needs to be dried prior to analysis it
should be done in a manner that does not result in loss of SO2 in
the sample as analysed.
6.8 The SO2
and CO2 values should be compared on the basis of the same residual
water content (e.g. dry or with the same wetness fraction).
6.9 In justified cases
where the CO2 concentration is reduced by the EGC unit, the CO2
concentration can be measured at the EGC unit inlet, provided that the
correctness of such a methodology can be clearly demonstrated. In such cases
the SO2 and CO2 values should be compared on a dry basis.
If measured on a wet basis the water content in the exhaust gas stream at those
points should also be determined in order to correct the readings to dry basis
values. For calculation of the CO2 value on a dry basis, the dry/wet
correction factor may be calculated in accordance with paragraph 5.12.3.2.2 of
the NOX Technical Code 2008.
7 DATA RECORDING AND
PROCESSING DEVICE
7.1 The
recording and processing device should be of robust, tamper-proof design with
read-only capability.
7.2 The
recording and processing device should record the data required by sections
4.4.7, 5.4.2, and 10.3 against UTC and ships position by a Global Navigational
Satellite System (GNSS).
7.3 The
recording and processing device should be capable of preparing reports over
specified time periods.
7.4 Data
should be retained for a period of not less than 18 months from the date of
recording. If the unit is changed over that period, the shipowner should ensure
that the required data is retained on board and available as required.
7.5 The
device should be capable of downloading a copy of the recorded data and reports
in a readily useable format. Such copy of the data and reports should be
available to the Administration or port State authority as requested.
8 ONBOARD MONITORING
MANUAL (OMM)
8.1 An
OMM should be prepared to cover each EGC unit installed in conjunction with
fuel oil combustion equipment, which should be identified, for which compliance
is to be demonstrated.
8.2 The
OMM should, as a minimum, include:
.1 the sensors to be used in evaluating EGC
system performance and washwater monitoring, their service, maintenance and
calibration requirements;
.2 the positions from which exhaust emission
measurements and washwater monitoring are to be taken together with details of
any necessary ancillary services such as sample transfer lines and sample
treatment units and any related service or maintenance requirements;
.3 the analysers to be used, their service,
maintenance, and calibration requirements;
.4 analyser zero and span check procedures; and
.5 other information or data relevant to the
correct functioning of the monitoring systems or its use in demonstrating
compliance.
8.3 The
OMM should specify how the monitoring is to be surveyed.
8.4 The
OMM should be approved by the Administration.
9 SHIP COMPLIANCE
9.1 SOX
Emissions Compliance Plan (SECP)
9.1.1 For
all ships which are to use an EGC unit, in part or in total, in order to comply
with the requirements of regulations 14.1 and 14.4 of MARPOL Annex VI there
should be an SECP for the ship, approved by the Administration.
9.1.2 The
SECP should list each item of fuel oil combustion equipment which is to meet
the requirements for operating in accordance with the requirements of
regulations 14.1 and/or 14.4 of MARPOL Annex VI.
9.1.3 Under
Scheme A, the SECP should present how continuous monitoring data will
demonstrate that the parameters in paragraph 4.4.7 are maintained within the
manufacturer's recommended specifications. Under Scheme B, this would be
demonstrated using daily recordings of key parameters.
9.1.4 Under
Scheme B, the SECP should present how continuous exhaust gas emissions
monitoring will demonstrate that the ship total SO2(ppm)/CO2(%) ratio is comparable to the
requirements of regulation 14.1 and/or 14.4 of MARPOL Annex VI or below as
prescribed in paragraph 1.3. Under Scheme A, this would be demonstrated using
daily exhaust gas emission recordings.
9.1.5 There
may be some equipment such as small engines and boilers to which the fitting of
EGC units would not be practical, particularly where such equipment is located
in a position remote from the main machinery spaces. All such fuel oil
combustion units should be listed in the SECP. For these fuel oil combustion
units which are not to be fitted with EGC units, compliance may be achieved by
means of regulations 14.1 and/or 14.4 of MARPOL Annex VI.
9.2 Demonstration of
compliance
9.2.1 Scheme A
9.2.1.1 The
SECP should refer to, not reproduce, the ETM-A, EGC Record Book or Engine-Room
logger system and OMM as specified under Scheme A. It should be noted that as
an alternative, the maintenance records may be recorded in the ship's planned
maintenance record system, as allowed by the Administration.
9.2.1.2 For
all fuel oil combustion equipment listed under paragraph 9.1.2, details should
be provided demonstrating that the rating and restrictions for the EGC unit as
approved, paragraph 4.2.2.1.2, are complied with.
9.2.1.3 Required
parameters should be monitored and recorded as required under paragraph 4.4.7
when the EGC is in operation in order to demonstrate compliance.
9.2.2 Scheme B
The SECP should refer to, not reproduce, the ETM-B, EGC Record
Book or Engine-Room logger system and OMM as specified under Scheme B.
10 WASHWATER
10.1 Washwater discharge criteria1
_________________________
1 The washwater discharge
criteria should be revised in the future as more data becomes available on the
contents of the discharge and its effects, taking into account any advice given
by GESAMP.
10.1.1 When the EGC system
is operated in ports, harbours, or estuaries, the washwater monitoring and
recording should be continuous. The values monitored and recorded should
include pH, PAH, turbidity and temperature. In other areas the continuous
monitoring and recording equipment should also be in operation, whenever the
EGC system is in operation, except for short periods of maintenance and
cleaning of the equipment. The discharge water should comply with the following
limits.
10.1.2 pH criteria
10.1.2.1 The washwater pH should comply with
one of the following requirements which should be recorded in the ETM-A or
ETM-B as applicable:
.1
The discharge washwater should have a pH of no less than 6.5 measured at the
ship's overboard discharge with the exception that during manoeuvring and
transit, the maximum difference between inlet and outlet of 2 pH units is
allowed measured at the ship's inlet and overboard discharge.
.2
The pH discharge limit, at the overboard monitoring position, is the value that
will achieve as a minimum pH 6.5 at 4 m from the overboard discharge point with
the ship stationary, and which is to be recorded as the overboard pH discharge
limit in the ETM-A or ETM-B. The overboard pH discharge limit can be determined
either by means of direct measurement, or by using a calculation-based
methodology (computational fluid dynamics or other equally scientifically
established empirical formulae) to be left to the approval by the
Administration, and in accordance with the following conditions to be recorded
in the ETM-A or ETM-B:
.1
all EGC units connected to the same outlets are operating at their full loads
(or highest practicable load) and with the fuel oil of a maximum sulphur
content for which the units are to be certified (Scheme A) or used with (Scheme
B);
.2 if a test fuel with lower sulphur content,
and/or test load lower than maximum, sufficient for demonstrating the behaviour
of the washwater plume is used, the plume's mixing ratio must be established
based on the titration curve of seawater. The mixing ratio would be used to
demonstrate the behaviour of the washwater plume and that the overboard pH
discharge limit has been met if the EGC system is operated at the highest fuel
sulphur content and load for which the EGC system is certified (Scheme A) or
used with (Scheme B);
.3 where the washwater flow rate is varied in
accordance with the EGC system gas flow rate, the implications of this for the
part load performance should also be evaluated to ensure that the overboard pH
discharge limit is met under any load;
.4 reference should be made to a sea-water
alkalinity of 2,200 μmol/litre
and pH 8.22; an amended titration curve should be applied where the
testing conditions differ from the reference seawater, as agreed by the
Administration; and
.5 if a calculation-based methodology is to be
used, details to allow its verification such as but not limited to supporting
scientific formulae, discharge point specification, washwater discharge flow
rates, designed pH values at both the discharge and 4 m location, titration and
dilution data should be submitted.
___________________________
2 These
values could be revised within two years for new installations following the
adoption of these amended guidelines upon further inputs on the physical state
of the seas resulting from the use of exhaust gas cleaning systems.
10.1.3 PAHs (Polycyclic Aromatic
Hydrocarbons)
10.1.3.1 The washwater PAH should comply with
the following requirements. The appropriate limit should be specified in the
ETM-A or ETM-B.
10.1.3.2 The maximum continuous PAH
concentration in the washwater should not be greater than 50 µg/L PAHphe
(phenanthrene equivalence) above the inlet water PAH concentration. For the
purposes of this criteria, the PAH concentration in the washwater should be
measured downstream of the water treatment equipment, but upstream of any
washwater dilution or other reactant dosing unit, if used, prior to discharge.
10.1.3.3 The 50 µg/L limit described above is
normalized for a washwater flow rate through the EGC unit of 45 t/MWh where the
MW refers to the MCR or 80% of the power rating of the fuel oil combustion
unit. This limit would have to be adjusted upward for lower washwater flow
rates per MWh, and vice-versa, according to the table below.
|
Flow rate (t/MWh) |
Discharge concentration
limit (µg/L PAHphe
equivalents) |
Measurement technology |
|
0-1 |
2250 |
Ultraviolet light |
|
2.5 |
900 |
– " – |
|
5 |
450 |
Fluorescence3 |
|
11.25 |
200 |
– " – |
|
22.5 |
100 |
– " – |
|
45 |
50 |
– " – |
|
90 |
25 |
– " – |
____________________
3 For any Flow Rate >
2.5 t/MWh Fluorescence technology should be used.
10.1.3.4 For a
15-minute period in any 12-hour period, the continuous PAHphe concentration
limit may exceed the limit described above by up to 100%. This would allow for
an abnormal start-up of the EGC unit.
10.1.4 Turbidity/Suspended
Particle Matter
10.1.4.1 The washwater turbidity should comply
with the following requirements. The limit should be recorded in the ETM-A or
ETM-B.
10.1.4.2 The washwater treatment system should
be designed to minimize suspended particulate matter, including heavy metals
and ash.
10.1.4.3 The maximum continuous turbidity in
washwater should not be greater than 25 FNU (formazin nephlometric units) or 25
NTU (nephlometric turbidity units) or equivalent units, above the inlet water
turbidity. However, during periods of high inlet turbidity, the precision of
the measurement device and the time lapse between inlet measurement and outlet
measurement are such that the use of a difference limit is unreliable.
Therefore all turbidity difference readings should be a rolling average over a
15-minute period to a maximum of 25 FNU. For the purposes of this criteria the
turbidity in the washwater should be measured downstream of the water treatment
equipment but upstream of washwater dilution (or other reactant dosing) prior to
discharge.