DNV GL EGC system approval and experience - Intertanko DNV GL MAR… · – Main Relevant Chapter:...

DNV GL © 2013 INTERTANKO TANKER EVENT, NEW YORK, 09 MAY 2014 SAFER, SMARTER, GREENERDNV GL © 2013

INTERTANKO TANKER EVENT, NEW YORK, 09 MAY 2014

Håkon B. Thoresen, Principal Approval Engineer

MARITIME

DNV GL EGC system approval and experience

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SOx Exhaust Gas Cleaning Systems (EGCs)

DNV GL © 2013 INTERTANKO TANKER EVENT, NEW YORK, 09 MAY 2014

SOx Exhaust 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

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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 2013.

• North American ECA in effect 1 Aug 2012 - 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)

-2020 in EU EEZ waters

Current status:

� More than 50 SOx Exhaust Gas Cleaning systems delivered to and to be

delivered on DNV GL classed ships and new building projects

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Publically announced recent and current SOx Exhaust Gas Cleaning systems on DNV classed ships - retrofit an new building projects

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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

IMO, ILO and other international bodies and organisations develop

international regulations. Flag States adopt these as own national

requirements through national legislation

� Port State

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

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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

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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)

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2013 EDITION


DNV Rules for Classification of Ships, Pt.4 Ch.6, July 2013

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DNV Rules for Classification of Ships, Pt.4 Ch.6, July 2013

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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

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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) §10.1.2.1 (wet systems only)

� Inclusion or Endorsement of EGC in IAPP by DNV GL or Flag

– MED certificate required for EU flagged vessels incl EFTA

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MARPOL Approval of open loop EGC Systems (Scheme B)

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MEPC.184(59) Scheme B

Approval of continuousexhaust 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

Endorse EGCS in IAPP certificate by DNV GL or Flag

Examination of final documents• SECP• OMM• ETM-B• EGC Record Book• Nitrate analysis certificate • DNV GL survey report• Final acceptance

Tim

e

Yes

No

Yes

No

Corrective action

Corrective action

NoCorrective action

Yes

No

Yes


MARPOL Approval of hybrid EGC Systems (Scheme B)

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MEPC.184(59) Scheme B

Approval of continuousexhaust 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

Endorse EGCS in IAPP certificate by DNV GL or Flag

Examination of final documents• SECP• OMM• ETM-B• EGC Record Book• Nitrate analysis certificate • DNV GL survey report• Final acceptance

Tim

e

Yes

No

Yes

No

Corrective action

Corrective action

NoCorrective action

Yes

No

Yes

Assessment of the washwater


Directive 2012/32/EU – MED certificate

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Water analysis for Nitrates ref MEPC.184(59) 10.1.5

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Example Nitrates in washwater overboard discharge10.1.5.1 The washwatertreatment 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


Notification by Flag to IMO

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Application of Regulation 4 of MARPOL Annex VIIMO MEPC.1 Circulars

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Water analysis acc .to MEPC.184(59) Appendix III(for data collection)

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Example seawater inlet (for background)

Example washwater overboard discharge


Example 1 - Inline wet hybrid scrubberfor RCCL - DNV ID. 26180 SiO

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LIBERTY OF THE SEAS Passenger Ship

Green Tech Marine AS1 x Open loop wet EGCs


Example 2 - Dry scrubbers FS G 757 for Oceanex, Canada DNV ID. 32310 NB

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OCEANEX CONNAIGRARoll-on/Roll-off Carrier

Couple Systems GmbH4 x dry EGCs


Example 3– Wet open loop scrubbersHYUNDAI H.I for Solvang ASA – DNV ID. 32114 NB

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CLIPPER QUITOLiquefied Gas Carrier (LPG)

Wärtsilä Moss2 x Open-loop wet EGC systems


IMO MEPC.184(59) 9 - SHIP COMPLIANCE.

“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 or

below as prescribed in paragraph 1.3.

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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.”

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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.”

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

“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.”

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IMO MEPC.184(59) Calculation, monitoring and logging of emission rate

“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.”

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IMO MEPC.184(59) EMISSION TESTING

“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”

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IMO MEPC.184(59) Sampling for gaseous emissions

“5.9.3 Sampling for gaseous emissions

5.9.3.1 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.

5.9.3.2 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.”

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IMO MEPC.184(59) 10.1.6 WASHWATER ADDITIVES

“10.1.6 WASHWATER ADDITIVES AND OTHER SUBSTANCES

10.1.6.1 An assessment of the washwater is 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. ”

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IMO MEPC.184(59) Washwater monitoring and recording

“10 WASHWATER

10.1 Washwater discharge criteria

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”

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IMO MEPC.184(59) Washwater monitoring and recording

10.3 Washwater monitoring data recording

10.3.1 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.

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IMO MEPC.184(59) 10.1.2.1 (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.

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Option 1 - MEPC.184 (59) § 10.1.2.1 (i) Vessel Stationary pH ≥ 6.5

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pH ≥ 6.5 pH measured at the ship's overboard discharge


Option 1 continue - MEPC.184 (59) § 10.1.2.1 (i) During transit or manoeuvring ∆ pH ≤ 2

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MANOEUVRING and TRANSIT The maximum difference between inlet and outlet of 2 pH units


Option 2 MEPC.184 (59) § 10.1.2.1 (ii) Vessel stationary - during commissioning pH 4m away ≥ 6.5

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DURING COMMISSIONING AT REST IN HARBOUR The plume at 4 metres from the discharge point equals or is above pH 6.5


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

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S.w. outlet (M11) and 4 m rod (one can observe discharge water coming out in centre of picture/diver unclear)

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(Courtesy: Wärtsilä/Immersub & Co.

Ltd)


pH probe 4 m away from s.w. outlet (M11). Note that the probe had to be vertical to function correctly

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(Courtesy: Wärtsilä/Immersub & Co.

Ltd)


pH monitoring instrument showing pH = 7.74 @ 4 m away from outlet M11 ( >= 6.5 pH)

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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) §9.1.1 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 14.4.

� According to MEPC.184(59) §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

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.

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Directive 2012/33/EU vs MARPOL Annex VI

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Source EMSA



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Source EMSA



43

Source EMSA



44Source EMSA


US EPA VESSEL GENERAL PERMIT (VGP) FINAL 2013

� § 2.2.26.1.1 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.”

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Scrubber Approval Process – Responsibilities and deliveries

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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) 10.1.2.1 (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)

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CFD image courtesy of J. Nash, DeFrees

Hydraulics Laboratory, Cornell University.


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

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Status and the way forward to 2020/2025

� SOx ECG systems capable of meeting the 0.10 % Sulphur limit 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

� SOx EGC open loop systems optimized to meet the 2020/2025 global

sulphur limit 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

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SAFER, SMARTER, GREENER

www.dnvgl.com

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[email protected]

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