DNV GL EGC system approval and experience

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1 MARITIME DNV GL EGC system approval and experience SOxExhaust Gas Cleaning Systems (EGCs) Håkon B. Thoresen, Principal Approval Engineer INTERTANKO TANKER EVENT, NEW YORK, 09 MAY SAFER, SMARTER, GREENER

2 SOxExhaust Gas Cleaning systems Introduction The Maritime Regime Exhaust Gas Cleaning systems in DNV GL DNV Rules for classification of ships MARPOL Annex VI and MEPC.184(59) EU MED Statutory verification according to MEPC.184(59) MARPOL vs EU Directive US EPA Recent developments in IMO Status and the way forward to 2020/2025 2

3 Introduction Background: SOx EGC systems are allowed as equivalent measures under: MARPOL Annex VI (Regulation 4) entered into force 1 July 2010 EU Directive 2012/33/EU dated 21 Nov 2012 US EPA Vessel General Permit (VGP) 19 Dec North American ECA in effect 1 Aug increased need for EGCs 0,10% m/m sulphur limit into force in ECAs 1 Jan 2015 (from 1.00% m/m) 0,50% m/m global sulphur limit into force 1 Jan 2020 or 2025 (from 3.50% m/m) Current status: in EU EEZ waters More than 50 SOxExhaust Gas Cleaning systems delivered to and to be delivered on DNV GL classed ships and new building projects 3

4 Publically announced recent and current SOx Exhaust Gas Cleaning systems on DNV classed ships - retrofit an new building projects 4 DNV GL 2013 INTERTANKO TANKER EVENT, NEW YORK, 09 MAY 2014

5 The Maritime Regime Flag State All ships have nationality and fly the corresponding flag. The ship has to satisfy requirements given by the national authorities i.e. the state whose flag the ship is intended to fly. International regulations Port State IMO, ILO and other international bodies and organisations develop international regulations. Flag States adopt these as own national requirements through national legislation Ship entering ports may be inspected by the Party State and may be detained if they do not meet specific Port requirements or if it is reason to believe that they do not meet international regulations Recognized Organizations The Flag States authorize Recognized Organizations (such as Class Societies) to certify that national and international requirements are satisfied 5

6 DNV GL as a Recognized Organization (RO) The Classification Society is responsible and accountable to the flag Administration for the work that it carries out on its behalf Should verify that a ship is in compliance with applicable requirements - Do a Survey - The survey scope laid by the flag Administration in compliance with the relevant international conventions to which it is a signatory 6

7 Plan and MARPOL Approval of EGC systems DNV GL Class approval process DNV GL Statutory Approval process in accordance with MARPOL Annex VI and MEPC.184(59) 2013 EDITION 7

8 DNV Rules for Classification of Ships, Pt.4 Ch.6, July

9 DNV Rules for Classification of Ships, Pt.4 Ch.6, July

10 Plan and MARPOL Approval of EGC Systems DNV Class approval process Covers system documentation, safety of ship main concern. Main Relevant Chapter: DNV Rules for Classification of Ships, Pt.4 Ch.6 (Piping systems) Installation also covered by other class rules as applicable. Machinery, Control Systems, Electrical Systems, Structure, Stability, Fire Safety Important to note requirements for class notation E0, RP DYNPOS, CLEAN DESIGN etc. if applicable Statutory Approval process in accordance with MARPOL Annex VI and MEPC.184(59) DNV GL act as Recognized Organization (RO) on behalf of the Flag 10

11 Plan and MARPOL Approval of EGC Systems (Scheme B) in accordance with MARPOL Annex VI and MEPC.184(59): Approval of continuous exhaust gas monitoring system, ref. MEPC.184(59) 5.2 FAT / certification of control and monitoring system prior to delivery from maker Examination of documents, Scheme B. SECP (SOx Emissions Compliance Plan) OMM (Onboard Monitoring Manual) ETM-B (EGCS Technical Manual for Scheme B) EGC Record Book or Electronic Logging System Test plan for commissioning, including test fuel Initial survey Check of EGC system operation, monitoring and data logging functions Verification of EGCs-SOx units according MARPOL Annex VI Verification of ph washwater criteria MEPC.184(59) (wet systems only) Inclusion or Endorsement of EGC in IAPP by DNV GL or Flag MED certificate required for EU flagged vessels incl EFTA 11

12 MARPOL Approval of open loop EGC Systems (Scheme B) MEPC.184(59) Scheme B Time Approval of continuous exhaust gas monitoring system Examination of preliminary documents SECP OMM ETM-B EGC Record Book Test plan for commissioning Initial survey Check of EGC system operation, monitoring and data logging functions Verification of EGCs-SOx units according MARPOL Annex VI Verification of ph washwater criteria Sampling of washwater at discharge point for nitrates analysis Examination of final documents SECP OMM ETM-B EGC Record Book Nitrate analysis certificate DNV GL survey report Final acceptance Yes Yes Yes Yes No No No No Corrective action Corrective action Corrective action Endorse EGCS in IAPP certificate by DNV GL or Flag 12

13 MARPOL Approval of hybrid EGC Systems (Scheme B) MEPC.184(59) Scheme B Time Approval of continuous exhaust gas monitoring system Assessment of the washwater Examination of preliminary documents SECP OMM ETM-B EGC Record Book Test plan for commissioning Initial survey Check of EGC system operation, monitoring and data logging functions Verification of EGCs-SOx units according MARPOL Annex VI Verification of ph washwater criteria Sampling of washwater at discharge point for nitrates analysis Examination of final documents SECP OMM ETM-B EGC Record Book Nitrate analysis certificate DNV GL survey report Final acceptance Yes Yes Yes Yes No No No No Corrective action Corrective action Corrective action Endorse EGCS in IAPP certificate by DNV GL or Flag 13

14 Directive 2012/32/EU MED certificate 14

15 Water analysis for Nitrates ref MEPC.184(59) The washwater treatment system should prevent the discharge of nitrates beyond that associated with a 12% removal of NOx from the exhaust, or beyond 60 mg/l normalized for washwater discharge rate of 45 tons/mwh whichever is greater Example Nitrates in washwater overboard discharge 15

16 Notification by Flag to IMO 16

17 Application of Regulation 4 of MARPOL Annex VI IMO MEPC.1 Circulars 17

18 Water analysis acc.to MEPC.184(59) Appendix III (for data collection) Example seawater inlet (for background) Example washwater overboard discharge 18

19 Example 1 - Inline wet hybrid scrubber for RCCL -DNV ID SiO LIBERTY OF THE SEAS Passenger Ship Green Tech Marine AS 1 x Open loop wet EGCs 19

20 Example2 -Dry scrubbers FS G 757 for Oceanex, Canada DNV ID NB OCEANEX CONNAIGRA Roll-on/Roll-off Carrier Couple Systems GmbH 4 x dry EGCs 20

21 Example 3 Wet open loop scrubbers HYUNDAI H.I for Solvang ASA DNV ID NB CLIPPER QUITO Liquefied Gas Carrier (LPG) Wärtsilä Moss 2 x Open-loop wet EGC systems 21

22 IMO MEPC.184(59) 9 - SHIP COMPLIANCE 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 or below as prescribed in paragraph

23 IMO MEPC.184(59) 5.1. CONTINUOUS MONITORING OF SOx 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. 23

24 IMO MEPC.184(59) Tamper proof 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. 24

25 IMO MEPC.184(59) Onboard procedures for demonstrating compliance 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, washwaterpressure 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. 25

26 IMO MEPC.184(59) Calculation, monitoring and logging of emission rate 5.4 Calculation of emission rate Exhaust gas composition in terms of SO 2 (ppm)/co 2 (%) 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 SO 2 (ppm) and CO 2 (%) to be continuously monitored and recorded onto a data recording and processing device at a rate which should not be less than Hz. 26

27 IMO MEPC.184(59) EMISSION TESTING 6 EMISSION TESTING 6.1 Emission testing should follow the requirements of the NOxTechnical Code 2008, chapter 5, and associated Appendices, except as provided for in these Guidelines 27

28 IMO MEPC.184(59) Sampling for gaseous emissions Sampling for gaseous emissions The sampling probes for the gaseous emissions shall be fitted at least 10 pipe diameters after the outlet of the engine, turbocharger, or last after-treatment device, whichever is furthest downstream, but also at least 0.5 m or 3 pipe diameters upstream of the exit of the exhaust gas system, whichever is greater. For a short exhaust system that does not have a location that meets both of these specifications, an alternative sample probe location shall be subject to approval by the Administration The exhaust gas temperature shall be at least 190 C at the HC sample probe, and at least 70 C at the sample probes for other measured gas species where they are separate from the HC sample probe. 28

29 IMO MEPC.184(59) WASHWATER ADDITIVES WASHWATER ADDITIVES AND OTHER SUBSTANCES An assessment of the washwateris required for those EGC technologies which make use of chemicals, additives, preparations or create relevant chemicals in situ. The assessment could take into account relevant guidelines such as resolution MEPC.126(53), procedure for approval of ballast water management systems that make use of active substances (G9) and if necessary additional washwater discharge criteria should be established. 29

30 IMO MEPC.184(59) Washwater monitoring and recording 10 WASHWATER 10.1 Washwater discharge criteria When the EGC system is operated in ports, harbours, or estuaries, the washwatermonitoring 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 30

31 IMO MEPC.184(59) Washwater monitoring and recording 10.3 Washwater monitoring data recording The data recording system should comply with the requirements of sections 7 and 8 and should continuously record ph, PAH and Turbidity as specified in the washwater criteria. 31

32 IMO MEPC.184(59) (i) & (ii) (i) The discharge wash water 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. OR (ii) During commissioning of the unit(s) after installation, the discharged wash water plume should be measured externally from the ship (at rest in harbour) and the discharge ph at the ship s overboard ph monitoring point will be recorded when the plume at 4 metres from the discharge point equals or is above ph 6.5. The discharged ph to achieve a minimum ph units of 6.5 will become the overboard ph discharge limit recorded in the ETM-A or ETM-B. 32

33 Option 1 -MEPC.184 (59) (i) Vessel Stationary ph 6.5 ph 6.5 ph measured at the ship's overboard discharge 33

34 Option 1 continue -MEPC.184 (59) (i) During transit or manoeuvring ph 2 MANOEUVRING and TRANSIT The maximum difference between inlet and outlet of 2 ph units 34

35 Option 2 MEPC.184 (59) (ii) Vessel stationary - during commissioning ph 4m away 6.5 DURING COMMISSIONING AT REST IN HARBOUR The plume at 4 metres from the discharge point equals or is above ph

36 Case : Verification of ph criteria ( ph >= 6,5) 4 meter away from s.w.discharge -At anchorage 36

37 S.w.outlet (M11) and 4 m rod (one can observe discharge water coming out in centre of picture/diver unclear) (Courtesy: Wärtsilä /Immersub & Co. Ltd) 37

38 ph probe 4 m away from s.w.outlet (M11). Note that the probe had to be vertical to function correctly (Courtesy: Wärtsilä /Immersub & Co. Ltd) 38

39 ph monitoring instrument showing ph = 4 m away from outlet M11 ( >= 6.5 ph) 39

40 Approval of EGC Systems - documentation Documentation for examination must be EGCs unit specific and vessel specific (not generic). Details of the EGC arrangement/mechanical drawings/p&id explaining the system and which engines are connected, part list and a description of the functions should be included with statutory approval documentation. According to MEPC.184(59) the documentation (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 According to MEPC.184(59) 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 documentation (SECP). Inclusion or Endorsement of EGCS in IAPP can only happen after commissioning and successful shipboard test in presence of a DNV GL Surveyor and successful examination of the final documents. 40

41 Directive 2012/33/EU vs MARPOL Annex VI Source EMSA 41

42 Directive 2012/33/EU vs MARPOL Annex VI Source EMSA 42

43 Directive 2012/33/EU vs MARPOL Annex VI Source EMSA 43

44 Directive 2012/33/EU vs MARPOL Annex VI 44 Source EMSA

45 US EPA VESSEL GENERAL PERMIT (VGP) FINAL ph. The discharge of wash water from the exhaust gas scrubber treatment system must have a ph of no less than 6.0 measured at the ship s overboard discharge, with the exception that during manoeuvring and transit, the maximum difference between inlet and outlet of 2.0 ph units is allowed. This difference is to be measured at the ship s inlet and overboard discharge. 45

46 Scrubber Approval Process Responsibilities and deliveries 46

47 Recent developments at IMO PPR1 in London, February 2014 Norway (in PPR 1/9/3) raised several issues that needs to be discussed in IMO. difficult to verify the ph criteria for main engine scrubbers for ships with conventional propulsion system with ship at rest in harbour. General agreement from the discussions that there is need for revision of 2009 Guidelines for Exhaust Gas Cleaning systems General support to discuss Computational Fluid Dynamics (CFD)/ plume modeling as an equivalent method for demonstration compliance in accordance with option 2 in MEPC.184(59) (ii). Submissions to MEPC 67 (13-17 Oct 2014) may be seen due to urgency of the matters SOx ECG systems is expected to be discussed further at PPR2 (19 to 23 January 2015) CFD image courtesy of J. Nash, DeFrees Hydraulics Laboratory, Cornell University. 47

48 Recent developments at IMO MEPC in London, April 2014 Terms of reference for the correspondence group for the fuel availability review developed (review shall to be completed by 2018) May impact demand for SOx EGC scrubbers Daft amendments to MARPOL Annex VI Fuel oil definition to include gas in addition to distillate and residual fuels Diesel engine definition to include gas fuelled engines 48

49 Status and the way forward to 2020/2025 SOxECG systems capable of meeting the 0.10 % Sulphurlimit in ECAs from 1-Jan 2015 : are commercially available and includes dry, wet open loop, hybrid are being ordered and installed on both newbuldings and retrofit with ECA operation after 1-Jan-2015 Inline scrubbers are becoming more popular due to compact and simple design Scheme B is preferred by the ship-owners Plume modeling as an equivalent method for demonstration compliance is needed where measurements 4 meter away cannot be done to verify compliance SOxEGC open loop systems optimized to meet the 2020/2025 global sulphurlimit of 0.50% sulphur+ MGO in ECA may be a solution for the high number of vessels with large 2-stroke engines operating mainly outside ECA Other equivalent methods are under development or expected to be developed 49

50 SAFER, SMARTER, GREENER 50

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