MEPC.259(68) 2015 Guidelines for exhaust gas cleaning systems

Guidelines superseded by resolution MEPC.340(77)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 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:

.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 manufacturers 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

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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.

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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 g/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 g/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

(g/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

"

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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




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