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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.


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

.


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


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


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


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


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



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



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



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



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



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



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



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



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



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


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



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)

Lloyd’s Register and variants of it are trading names of Lloyd’s Register Group Limited, its subsidiaries and affiliates.Copyright © Lloyd’s Register EMEA. 2014. A member of the Lloyd’s Register group.

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

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