This procedure applies to all vessels equipped with Exhaust Gas Cleaning System. Exhaust from the below equipment is connected to the EGCS:
· Main Engine
· Auxiliary Engines
· Boiler* (as applicable)
- Note: If boilers are not connected to EGCS then change these over to compliant fuel prior to entering ECA
RESPONSIBILITIES
Master is responsible for:
· Requesting local regulation from agents for any restrictions for uses of EGCS and discharging its wash water/effluent within port limits/ territorial waters.
· Informing the office of any malfunctions of EGCS.
Chief Engineer is responsible for:
· EGCS operation and maintenance.
· Selecting relevant modes according to trading area requirements.
· Record keeping.
· EGCS training for operational procedures, maintenance, and safety aspects.
EGCS COMPLIANCE PRINCIPLE
Gas Emission from the EGCS
EGCS reduce Sulphur Dioxide (SO2) in the exhaust gas combustion unit. We achieve this by washing and scrubbing with seawater and additionally using Sodium Hydroxide, where applicable. Continuous emission monitoring system measures SO2/ CO2 ratio at the scrubber exhaust outlet.
SO2 (ppm) / CO2 (% v/v) ratio compliance values are:
| Fuel oil Sulphur content (% m/m) | Ratio emission SO2(ppm) / CO2 (% v/v) |
| 0.50 | 21.70 |
| 0.10 | 4.30 |
WASH WATER DISCHARGE CRITERIA
Wash water monitoring system measures below parameter prior to discharge for complying with the regulations.
· pH
· PAH
· Turbidity
The monitoring and recording equipment shall always be in operation whenever the EGCS is in operation, except during periods of maintenance and cleaning.
Note: Many ports restrict the usage of open-loop scrubbers due to the water discharge component even if the scrubber can comply with the emission criteria.
The wash water discharge overboard shall comply with the following limits:
| Parameter | Limits | Exceptions |
| pH | · 2 pH units between the inlet and outlet while the vessel is moving · Minimum pH 6.5 at 4 m from the overboard discharge point with the ship stationary | |
| PAH’s- Polycyclic Aromatic Hydrocarbon | · Maximum differential with the inlet water PAH concentration * | For a 15 min period in any 12-Hour period, the continuous PAH discharge limit may be exceeded by 100% |
| Turbidity | · Maximum differential with the inlet water turbidity | For a 15 min period in any 12-Hour period, the continuous PAH discharge limit may be exceeded by 20 % |
Warning: Do not incinerate residues collected manually for the scrubber operations. It shall be stored/segregated separately for shore disposal.
Wash Water Sample Analysis & Monitoring
In conjunction with the EGCS manufacturers, regular sampling of the below shall be carried out:
· Inlet water (for backgrounds)
· Water after the scrubber (but before any treatment system); and
· Discharge water
Test first sampling during EGCS approval or shortly after commissioning. Thereafter as per PMS requirements.
External parties require nitrate data at least 3 months prior to the renewal survey. However, the flag may require additional samples. Retain the nitrate discharge data and analysis certificate on board.
Follow VGP guidelines for sample collection & shore analysis, if the EGCS water is discharged within VGP waters.
EGCS RECORD KEEPING & DATA MONITORING
Maintain following records
Onboard Monitoring Manual (OMM) maintenance records
EGCS maintenance records
· Daily spot checks – vessel position, emission & wash water monitoring
· Daily spot checks – Operational parameters
· Onboard maintenance
· Malfunctions including resolving method and action plan
· Non-compliance along with corrective actions and follow-up actions
· Wash water nitrate concentration
· Calibration & maintenance of gas analyzer
· Calibration & maintenance of PAH analyzer
· Calibration & maintenance of pH analyzer
· Calibration & maintenance of turbidity
Maintain the following vessel-specific documents
· Class Approval Letter
· Survey Reports
· OMM: Onboard Monitoring Manual
· SECP: Sulphur Emission Compliance Manual
· Revised IAPP Certificate and supplements
· Flag stat’s statement for certifying usages of equivalent arrangements (EGCS)
a) Data Monitoring
EGCS inbuilt recording unit shall be capable of:
· Preparing reports over a specified time period
· Downloading a copy of the recorded data in a readable format
Retain the data onboard for at least the last 18 months
Note: If you are replaced the recording unit, retain onboard data at least 18 months.
CONTINGENCY PLAN
EGCS malfunction is any condition that leads to an emission exceedance, with the below expectations:
· Short-term temporary emission exceedance, or
· Interim indication of ongoing compliance in case of sensor failure
As soon as possible after evidence of a malfunction ( eg. Alarm is triggered), the ship staff should take action to identify and rectify the malfunction.
An EGCS malfunction event should be included in the EGCS Record book including the date and time the, malfunction began and, if relevant, how it was resolved and the action taken to resolve it and any necessary follow-up action. If you cannot put back EGCS into a complaint condition within one hour after a breakdown, the vessel should change over to compliant fuel oil.
Notification to relevant authorities
Any EGCS malfunction that lasts more than one hour, or repetitive short-term malfunctions is to be reported to the flag state and relevant port state administration through the office. An explanation of the steps the ship taking to address the failure should be mentioned.
If the vessel does not have compliant fuel or sufficient quantity on board, a proposed course of action which includes bunkering compliant fuel oil or carrying out repair works should be communicated to relevant authorities including the ship’s administration, for their agreement.
If their discretion, the flag, and port state’s administration could take such information and other relevant circumstances into account to determine the appropriate action to take in the case of an EGCS malfunction, including not taking action.
Short-Term Exceedances
This is a temporary exceedance of the emission ration. Sudden changes in exhaust gas flow rate to the EGCS may cause this.
A time lapse between when the sensor takes its reading and when the unit responds may trigger an alarm from the continuous emission monitoring device even if the EGCS has not malfunctioned.
Thus, the transitory period and isolated spikes in the recorded output do not necessarily mean the exceedance of emissions.
Interim Indication of Ongoing Compliance in case of Sensor Failure
All monitored emission ration and wash water parameters are interdependent. Changes in one parameter will also result in changes in order.
Thus, if one parameter changes and another parameter continues at the normal emission ration at the normal levels, this is a probable indication of instrument malfunction and not non-compliances
If a malfunction occurs in the instrumentation for the monitoring of emission ration or discharge water (pH, PAH, Turbidity), keep below records of interim indication for demonstration compliance.
· Manual and automatic recording of the data at the time of the malfunction
· Sulphur content of the various grades of fuel used in the affected engine after the malfunctions started
· Log of defective monitoring equipment
· All parameter that proves compliant operation until the defect is rectified.
· Action plan for rectifying the defect.
Restriction and Limitation
Ensure compliance with regulation MEPC.259(68), US VGP and local restrictions.
Warning!
Do not use open-loop scrubbers within port limits without confirming with local agents
References
· MARPOL 73/78
· Resolution MEPC.259(68) 2015 Guidelines for exhaust gas cleaning system
· MEPC.1/Circ.883 Guidance on the indication of ongoing compliance in the case of failure of a single monitoring instrument
