MEPC.184(59) 2009 Guidelines for Exhaust Gas Cleaning Systems

Guidelines superseded by resolution MEPC.259(58)

 

Resolution MEPC.184(59)

2009 GUIDELINES FOR EXHAUST GAS CLEANING SYSTEMS

(Adopted on 17 July 2009)

 

 

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 conferred upon it by international conventions for the prevention and control of marine pollution,

 

RECALLING ALSO that MARPOL Annex VI entered into force on 19 May 2005,

 

RECALLING FURTHER resolution MEPC.170(57) by which the Committee adopted the Guidelines for exhaust gas cleaning system,

 

NOTING that the revised MARPOL Annex VI was adopted by resolution MEPC.176(58) which is expected to enter into force on 1 July 2010,

 

NOTING ALSO that regulation 4 of the revised MARPOL Annex VI allows the use of an alternative compliance methods at least as effective in terms of emission reductions as that required by the revised 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 revise the Guidelines for exhaust gas cleaning systems, in accordance with provisions of the revised MARPOL Annex VI,

 

HAVING CONSIDERED the 2009 Guidelines for exhaust gas cleaning systems prepared by the Sub-Committee on Bulk Liquids and Gases at its thirteenth session,

 

1. ADOPTS the 2009 Guidelines for exhaust gas cleaning systems, as set out in the Annex to this resolution;

 

2. INVITES Governments to apply the 2009 Guidelines from 1 July 2010;

 

3. URGES Administrations to provide for collection of data under Appendix III; and

 

4. REVOKES the Guidelines adopted by resolution MEPC.170(57) as from 1 July 2010.

 

Annex.

2009 GUIDELINES FOR EXHAUST GAS CLEANING SYSTEMS

 

1. INTRODUCTION

 

1.1 Regulation 14 of Annex VI to MARPOL 73/78 requires ships to use fuel oil with a sulphur content not exceeding that stipulated in regulation 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 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 II 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 II for application of the ratio method.

 

1.4 These Guidelines are recommendatory in nature; however, Administrations are invited to base their implementation on these Guidelines.

 

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 exhaust gas cleaning (EGC) systems under regulation 4 to ensure that they provide effective equivalence to requirements of regulations 14.1 and 14.4 of Annex VI of MARPOL 73/78.

 

2.1.2 The 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

 

3.1 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 ships seawater inlet. In all operating conditions the pH should be maintained at a level that avoids damage to the vessels 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:

 

a) Unit approval;

 

b) Serially manufactured units;

 

c) 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 manufacturers specified maximum % m/m sulphur content and for the range of operating parameters, as listed in 4.2.2.1(b), 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 manufacturers 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 manufacturers 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 4.2.2.1(b) 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 4.2.2.1(b).

 

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 4.2.2.1(b). 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 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 4.2.1.1 should be issued with a SECC by the Administration. The form of the SECC is given in Appendix I.

 

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 4.2.1.1 may be issued with an SECC by the Administration without the need for testing in accordance with 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 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 down stream 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:

 

(a) 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;

 

(b) the operating limits, or range of operating values, for which the unit is certified. These should, as a minimum, include:

 

(i) maximum and, if applicable, minimum mass flow rate of exhaust gas;

 

(ii) 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;

 

(iii) maximum and minimum washwater flow rate, inlet pressures and minimum inlet water alkalinity (ISO 9963-1-2);

 

(iv) exhaust gas inlet temperature ranges and maximum and minimum exhaust gas outlet temperature with the EGC unit in operation;

 

(v) 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;

 

(vi) salinity levels or fresh water elements necessary to provide adequate neutralizing agents; and

 

(vii) other factors concerning the design and operation of the EGC unit relevant to achieving a maximum emission value no higher than the Certified Value;

 

(c) 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;

 

(d) 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;

 

(e) corrective actions in case of exceedances of the applicable maximum allowable SO2/CO2 ratio, or wash water discharge criteria;

 

(f) 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);

 

(g) through range performance variation in washwater characteristics; (h) design requirements of the washwater system; and

 

(i) 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. The ETM-A 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 the ETM-A.

 

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 MARPOL Annex VI regulation 10, 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 4.2.3.1, section 2.6 of the Supplement to the ships 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 within 4.2.2.1(b), 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 4.3.1 at all loads between 25-100% 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 4.3.1 at all loads between 10-100% 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 4.3.3.

 

4.3.5 EGC units fitted to boilers should meet the requirements of 4.3.1 at all loads between 10-100% 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 95-100% 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 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




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