exhaust gas cleaning system guidelines an update –may 2017 · 2019-02-10 · lloyd’s register...
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Working togetherfor a safer world
Exhaust Gas Cleaning System Guidelines
An Update – May 2017
Lloyd’s Register FOBAS
MARPOL Annex VI
Regulation 14 Sulphur oxides and particulate matter
Limits the sulphur content of any fuel oil used outside or inside ECA-SOx
Regulation 4 Equivalents
.1 The Administration of a Party may allow any fitting, material, appliance or apparatus to be fitted in a ship or other procedures, alternative fuel oils, or compliance methods used as an alternative to that required by this Annex if such fitting, material, appliance or apparatus or other procedures, alternative fuel oils, or compliance methods are at least as effective in terms of emissions reductions as that required by this Annex, including any of the standards set forth in regulations 13 and 14.
.3 The Administration of a Party should take into account any relevant guidelines developed by the Organization pertaining to the equivalents provided for in this regulation.
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IMO & IMO Instruments
Conventions
SOLAS, MARPOL ….. (…shall...)
Codes
NOx Technical Code 2008… (…shall…)
Guidelines
Communication from a UN technical organization (IMO) to sovereign states offering a standard base template (…should…) from which they are invited to develop their national requirements (…shall…) as applied either directly or via their Recognized Organisations
.
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EGCS Guidelines – History
MARPOL Annex VI – adopted 1997, entered into force 2005
MEPC.130(53) - 2005
Initial version. Application of Regulation 14(4)(b) – overall 6.0 g SOx / kWh – technology neutral, includes SO2/CO2 ratio as an option, basic wash water controls
MEPC.170(57) – 2008
Amendments introduce specific ‘wash water’ controls: pH, PAH, Turbidity (+ Nitrates)
MEPC.184(59) – 2009
Re-write. Equivalent to applicable amended Annex VI Regulation 14.1 / 14.4 requirements
SO2/CO2 ratio as the sole means of demonstrating compliance
Each combustion unit compliant rather than the ship in total
MEPC.259(68) - 2015
Minor changes; provides for wet CO2 measurement and pH limit at discharge by calculation
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EGCS Guideline Proposed Amendment
Agreed to consider – MEPC 69
Submission to MEPC 71
MEPC 71/9/1
EU Member States & EC
Developed by ESSF-EGCS SG
10 Meetings – 21 Rounds
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EGCS Guideline Amendment – Expected IMO Progression
MEPC 71 July 2017
PPR 5 Early 2018
MEPC 72 Spring 2018
Correspondence Group
MEPC 73 Autumn 2018
PPR 6 Early 2019
MEPC 74 Summer 2019
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EGCS Guideline Proposed AmendmentCore Components Unchanged
Emission Ratio - SO2 / CO2
Approved Documentation - ETM, OMM & SECP
Scheme A or Scheme BCertified EGCS Agreed Monitoring System
Parameter Monitoring Emission Ratio Monitoring
Daily Emission Ratio Check Daily Parameter Check
Data Recording & Retention
Discharge Water - pH, PAH & Turbidity + Nitrates
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EGCS Guideline Proposed Amendment - Sections
1 Introduction
2 General
3 Safety Note
4 Scheme A: Approval, Survey & Certification
5 Scheme B: Approval, Survey & Certification
6 Emission Testing
` 7 Data Recording & Processing
8 Onboard Monitoring Manual
9 Ship Compliance
10 Discharge Water
Appendices 1 - 5
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EGCS Guideline Proposed Amendment
Section 1 - Introduction
Extend application to other than ‘wet wash’ systems – subject to ‘special consideration’ and reporting to MEPC – further detail in Section 2
Remove reference to NOx Technical Code
Emission Ratio as the generally used term
– remove 4.50% and 1.00% ratios
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EGCS Guideline Proposed Amendment
Section 2 - General
Revised to provide a clearer summary of the Guidelines and the application of Sections to Scheme A / Scheme B
Definitions amended and expanded
Emission Ratio
Closed loop mode
Open loop mode
Discharge water
Wash water
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EGCS Guideline Proposed Amendment
Section 4 – Scheme A
Clarification of Emission Ratio compliance at all loads irrespective of machinery type or usage
Removal of text specific to application mode & idling
Clarification of Emission Ratio daily check requirement and minimum data requirement
ETM to also include:
design maximum fuel oil sulphur content
washwater and discharge water characteristics across load range and basis of treatment / monitoring design arrangements
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EGCS Guideline Proposed Amendment
Section 5 – Scheme B
Clarification of extent of approval
Clarification regarding operation of the EGCS at survey
Monitoring requirements clarified plus zero and span check data
ETM to also include:
design maximum fuel oil sulphur content
washwater and discharge water characteristics across load range and basis of treatment / monitoring design arrangements
Clarification regarding Record Book requirement
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EGCS Guideline Proposed Amendment
Section 6 – Emission Testing
Reference to NOx Technical Code retained but on a general basis –analysers to be operated, maintained and serviced at a frequency which
ensures required performance achieved
Extractive sampling system leak testing
SO2 span gas requirement
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EGCS Guideline Proposed Amendment
Section 7 – Data Recording and Processing
Clarification of what is to be recorded and when including whether ship is outside / inside an ECA-SOx
System to be capable of being set with the relevant limit and then capable of preparing and downloading reports covering requested period as to any exceedences
Description of system in the OMM
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EGCS Guideline Proposed Amendment
Section 8 – Onboard Monitoring Manual
Expanded and clarified as to what is to be included
Exhaust gas testing equipment / system arrangements
Discharge water testing equipment / system arrangements
Operating parameter monitors
Zero and span check requirements
Data recording device
Maintenance of analyser and equipment performance
Malfunction guidance
Survey of the monitoring equipment / systems
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EGCS Guideline Proposed Amendment
Section 9 – Ship Compliance
Extensively rewritten to fully reflect the changes introduced by the 2008 MARPOL Annex VI amendments
Which combustion equipment is / is not fitted with EGCS
When it is intended that the EGCS will be used
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EGCS Guideline Proposed Amendment
Section 10 – Discharge Water
Initial nitrate discharge check
General acceptance of sodium hydroxide as a system chemical
Discharge from holding or other tanks now covered
Clarification on discharge water monitoring requirements
Approval, recording and maintenance of discharge water monitoring
systems
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EGCS Guideline – Discharge Water PAH Limit
Limit: PAH 50 µg/l normalised to 45 t /MWh
MW the rated power of the working combustion system(s)
t/h the water flow rate at the point where PAH is measured
Works for:
• Both open loop and closed loop systems
• Where multiple combustion units feed into a single EGCS
• Where multiple EGCS feed into a single cleaning system
Basis: Maximum allowable PAH of 2.2 g/h per MW
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EGCS Guideline Proposed Amendment
Outstanding Issues
PAH – ‘phenanthrene equivalent’
PAH limit re holding, or other, tank discharges
Robustness of PAH detection
Application of nitrate controls
Turbidity ‘false’ zero
Non-Compliance
Failure of EGCS
Failure of EGCS monitoring system
Temporary monitoring fluctuations (Emission Ratio & pH)
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Working togetherfor a safer world
Andy Wright
Consultant – Fuels and Air Pollution Controls
TID – Ship Performance Group
Lloyd’s Register
GTC - Southampton
UK
T +44 (0)33041 40573
E [email protected] www.lr.org/marine
2017