Exhaust Gas Cleaning System Guidelines An Update May 2017

Transcription

1 Exhaust Gas Cleaning System Guidelines An Update May 2017 Working together for a safer world

2 MARPOL Annex VI Regulation 14 Sulphur oxides and particulate matter Limits the sulphur content of any fuel oil used outside or inside ECA-SO x 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 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.

3 IMO & IMO Instruments Conventions. Codes Guidelines SOLAS, MARPOL.. ( shall...) NO x Technical Code 2008 ( shall ) 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

4 EGCS Guidelines History MARPOL Annex VI adopted 1997, entered into force 2005 MEPC.130(53) Initial version. Application of Regulation 14(4)(b) overall 6.0 g SO x / kwh technology neutral, includes SO 2 /CO 2 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 SO 2 /CO 2 ratio as the sole means of demonstrating compliance Each combustion unit compliant rather than the ship in total MEPC.259(68) Minor changes; provides for wet CO 2 measurement and ph limit at discharge by calculation

5 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

6 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

7 Core Components Unchanged Emission Ratio - SO 2 / CO 2 Approved Documentation - ETM, OMM & SECP Scheme A or Scheme B Certified EGCS Parameter Monitoring Daily Emission Ratio Check Data Recording & Retention Agreed Monitoring System Emission Ratio Monitoring Daily Parameter Check Discharge Water - ph, PAH & Turbidity + Nitrates

8 - 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

9 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

10 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

11 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 data requirement minimum 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

12 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

13 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 SO 2 span gas requirement

14 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

15 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

16 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

17 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 systems monitoring

18 EGCS Guideline Discharge Water PAH Limit Limit: PAH 50 µg/l normalised to 45 t /MWh MW t/h the rated power of the working combustion system(s) 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

19 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)

20 Andy Wright Consultant Fuels and Air Pollution Controls TID Ship Performance Group Lloyd s Register GTC - Southampton UK T +44 (0) E andy.wright@lr.org w Working together for a safer world 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 A member of the Lloyd s Register group.