4.1 Approval of EGC systems
4.1.1 General
Options under Scheme A of these guidelines provide for:
- .1 unit approval;
- .2 serially manufactured units; and
- .3 production range approval.
4.1.2 Unit approval
4.1.2.1 An EGC unit should be certified as capable of meeting the limit
value, (the Certified Value), specified by the manufacturer (e.g. the emission level the
unit is capable of achieving on a continuous basis) with fuel oils of the manufacturer’s
specified maximum % m/m sulphur content and for the range of operating parameters, as
listed in paragraph 4.2.2.1.2, for which they are to be approved. The Certified Value
should at least be suitable for ship operations under requirements given by MARPOL Annex
VI regulations 14.1 and/or 14.4.
4.1.2.2 Where testing is not to be undertaken with fuel oils of the
manufacturer's specified maximum % m/m sulphur content, the use of two test fuels with a
lower % m/m sulphur content is permitted. The two fuels selected should have a
difference in % m/m sulphur content sufficient to demonstrate the operational behaviour
of the EGC unit and to demonstrate that the Certified Value can be met if the EGC unit
were to be operated with a fuel of the manufacturer's specified maximum % m/m sulphur
content. In such cases a minimum of two tests, in accordance with section 4.3 as
appropriate, should be performed. These need not be sequential and could be undertaken
on two different, but identical, EGC units.
4.1.2.3 The maximum and, if applicable, minimum exhaust gas mass flow rate of
the unit should be stated. The effect of variation of the other parameters defined in
paragraph 4.2.2.1.2 should be justified by the equipment manufacturer. The effect of
variations in these factors should be assessed by testing or otherwise as appropriate.
No variation in these factors, or combination of variations in these factors, should be
such that the emission value of the EGC unit would be in excess of the Certified Value.
4.1.2.4 Data obtained in accordance with this section should be submitted to
the Administration for approval together with the ETM-A.
4.1.3 Serially manufactured units
In the case of nominally similar EGC units of the same mass flow ratings as
that certified under 4.1.2, and to avoid the testing of each EGC unit, the equipment
manufacturer may submit, for acceptance by the Administration, a conformity of
production arrangement. The certification of each EGC unit under this arrangement should
be subject to such surveys that the Administration may consider necessary as to assure
that each EGC unit has an emission value of not more than the Certified Value when
operated in accordance with the parameters defined in paragraph 4.2.2.1.2.
4.1.4 Product range approval
4.1.4.1 In the case of an EGC unit of the same design, but of different maximum exhaust
gas mass flow capacities, the Administration may accept, in lieu of tests on an EGC unit
of all capacities in accordance with section 4.1.2, tests of EGC systems of three
different capacities provided that the three tests are performed at intervals including
the highest, lowest and one intermediate capacity rating within the range.
4.1.4.2 Where there are significant differences in the design of EGC units of different
capacities, this procedure should not be applied unless it can be shown, to the
satisfaction of the Administration, that in practice those differences do not materially
alter the performance between the various EGC unit types.
4.1.4.3 For EGC units of different capacities, the sensitivity to variations in the type
of combustion machinery to which they are fitted should be detailed together with
sensitivity to the variations in the parameters listed in paragraph 4.2.2.1.2. This
should be on the basis of testing, or other data as appropriate.
4.1.4.4 The effect of changes of EGC unit capacity on washwater characteristics should be
detailed.
4.1.4.5 All supporting data obtained in accordance with this section, together with the
ETM-A for each capacity unit, should be submitted to the Administration for approval.
4.2 Survey and certification
4.2.1 Procedures for the certification of an EGC unit
4.2.1.1 In order to meet the requirements of section 4.1 either prior to, or after
installation on board, each EGC unit should be certified as meeting the Certified Value
specified by the manufacturer (e.g. the emission level the unit is capable of achieving
on a continuous basis) under the operating conditions and restrictions as given by the
EGC Technical Manual (ETM-A) as approved by the Administration.
4.2.1.2 Determination of the Certified Value should be in accordance with the provisions
of these guidelines.
4.2.1.3 Each EGC unit meeting the requirements of paragraph 4.2.1.1 should be issued with
a SECC by the Administration. The form of the SECC is given in appendix 1.
4.2.1.4 Application for an SECC should be made by the EGC system manufacturer, shipowner
or other party.
4.2.1.5 Any subsequent EGC units of the same design and rating as that certified under
paragraph 4.2.1.1 may be issued with an SECC by the Administration without the need for
testing in accordance with paragraph 4.2.1.1 subject to section 4.1.3 of these
guidelines.
4.2.1.6 EGC units of the same design, but with ratings different from that certified
under paragraph 4.2.1.1 may be accepted by the Administration subject to section 4.1.4
of these guidelines.
4.2.1.7 EGC units which treat only part of the exhaust gas flow of the uptake in which
they are fitted should be subject to special consideration by the Administration to
ensure that under all defined operating conditions that the overall emission value of
the exhaust gas downstream of the system is no more than the Certified Value.
4.2.2 EGC System Technical Manual "Scheme A" (ETM-A)
4.2.2.1 Each EGC unit should be supplied with an ETM-A provided by the
manufacturer. This ETM-A should, as a minimum, contain the following information:
- .1 the identification of the unit (manufacturer, model/type, serial
number and other details as necessary) including a description of the unit and
any required ancillary systems;
- .2 the operating limits, or range of operating values, for which
the unit is certified. These should, as a minimum, include:
- .1 maximum and, if applicable, minimum mass flow rate of
exhaust gas;
- .2 the power, type and other relevant parameters of the fuel
oil combustion unit for which the EGC unit is to be fitted. In the cases
of boilers, the maximum air/fuel ratio at 100% load should also be
given. In the cases of diesel engines whether the engine is of 2 or
4-stroke cycle;
- .3 maximum and minimum washwater flow rate, inlet pressures
and minimum inlet water alkalinity (ISO 9963-1-2);
- .4 exhaust gas inlet temperature ranges and maximum and
minimum exhaust gas outlet temperature with the EGC unit in
operation;
- .5 exhaust gas differential pressure range and the maximum
exhaust gas inlet pressure with the fuel oil combustion unit operating
at MCR or 80% of power rating whichever is appropriate;
- .6 salinity levels or fresh water elements necessary to
provide adequate neutralizing agents; and
- .7 other factors concerning the design and operation of the
EGC unit relevant to achieving a maximum emission value no higher than
the Certified Value;
- .3 any requirements or restrictions applicable to the EGC unit or
associated equipment necessary to enable the unit to achieve a maximum emission
value no higher than the Certified Value;
- .4 maintenance, service or adjustment requirements in order that
the EGC unit can continue to achieve a maximum emission value no higher than the
Certified Value. The maintenance, servicing and adjustments should be recorded
in the EGC Record Book;
- .5 corrective actions in case of exceedances of the applicable
maximum allowable SO2/CO2 ratio, or wash water discharge
criteria;
- .6 a verification procedure to be used at surveys to ensure that
its performance is maintained and that the unit is used as required (see section
4.4);
- .7 through range performance variation in washwater
characteristics;
- .8 design requirements of the washwater system; and
- .9 the SECC.
4.2.2.2 The ETM-A should be approved by the Administration.
4.2.2.3 The ETM-A should be retained on board the ship onto which the EGC unit is fitted
and should be available for surveys as required.
4.2.2.4 Amendments to the ETM-A which reflect EGC unit changes that affect performance
with respect to emissions to air and/or water should be approved by the Administration.
Where additions, deletions or amendments to the ETM-A are separate to the ETM-A as
initially approved, they should be retained with the ETM-A and should be considered as
part of it.
4.2.3 In-service surveys
4.2.3.1 The EGC unit should be subject to survey on installation and at initial,
annual/intermediate and renewals surveys by the Administration.
4.2.3.2 In accordance with regulation 10 of MARPOL Annex VI, EGC units may also be subject
to inspection by port State control.
4.2.3.3 Prior to use, each EGC unit should be issued with an SECC by the Administration.
4.2.3.4 Following the installation survey as required by paragraph 4.2.3.1, section 2.6
of the Supplement to the ship's International Air Pollution Certificate should be duly
completed.
4.3 Emission limits
4.3.1 Each EGC unit should be capable of reducing emissions to equal to or less than the
Certified Value at any load point when operated in accordance with the criteria as given
in paragraph 4.2.2.1.2, as specified in paragraphs 4.3.2 to 4.3.5 of these guidelines,
and as excepted in paragraph 4.3.7.
4.3.2 EGC units fitted to main propulsion diesel engines should meet the requirements of
paragraph 4.3.1 at all loads between 25 to 100% of the load range of the engines to
which they are fitted.
4.3.3 EGC units fitted to auxiliary diesel engines should meet the requirements of
paragraph 4.3.1 at all loads between 10 to 100% of the load range of the engines to
which they are fitted.
4.3.4 EGC units fitted to diesel engines which supply power for both main propulsion and
auxiliary purposes should meet the requirements of paragraph 4.3.3.
4.3.5 EGC units fitted to boilers should meet the requirements of paragraph 4.3.1 at all
loads between 10 to 100% of the load range (steaming rates) or, if the turn down ratio
is smaller, over the actual load range of the boilers to which they are fitted.
4.3.6 In order to demonstrate performance, emission measurements should be undertaken,
with the agreement of the Administration, at a minimum of four load points. One load
point should be at 95 to 100% of the maximum exhaust gas mass flow rate for which the
unit is to be certified. One load point should be within ± 5% of the minimum exhaust gas
mass flow rate for which the unit is to be certified. The other two load points should
be equally spaced between the maximum and minimum exhaust gas mass flow rates. Where
there are discontinuities in the operation of the system the number of load points
should be increased, with the agreement of the Administration, so that it is
demonstrated that the required performance over the stated exhaust gas mass flow rate
range is retained. Additional intermediate load points should be tested if there is
evidence of an emission peak below the maximum exhaust gas mass flow rate and above, if
applicable, the minimum exhaust gas flow rate. These additional tests should be
sufficient number as to establish the emission peak value.
4.3.7 For loads below those specified in paragraphs 4.3.2 to 4.3.5, the EGC unit should
continue in operation. In those cases where the fuel oil combustion equipment may be
required to operate under idling conditions, the SO2 emission concentration
(ppm) at standardized O2 concentration (15.0% diesel engines, 3.0% boilers)
should not exceed 50 ppm.
4.4 Onboard procedures for demonstrating compliance
4.4.1 For each EGC unit, the ETM-A should contain a verification procedure for use at
surveys as required. This procedure should not require specialized equipment or an
in-depth knowledge of the system. Where particular devices are required they should be
provided and maintained as part of the system. The EGC unit should be designed in such a
way as to facilitate inspection as required. The basis of this verification procedure is
that if all relevant components and operating values or settings are within those as
approved, then the performance of the EGC system is within that required without the
need for actual exhaust emission measurements. It is also necessary to ensure that the
EGC unit is fitted to a fuel oil combustion unit for which it is rated – this forms part
of the SECP. A Technical File related to an EIAPP certificate, if available, or an
Exhaust Gas Declaration issued by the engine maker or designer or another competent
party or a Flue Gas Declaration issued by the boiler maker or designer or another
competent party serves this purpose to the satisfaction of the Administration.
4.4.2 Included in the verification procedure should be all components and operating
values or settings which may affect the operation of the EGC unit and its ability to
meet the Certified Value.
4.4.3 The verification procedure should be submitted by the EGC system manufacturer and
approved by the Administration.
4.4.4 The verification procedure should cover both a documentation check and a physical
check of the EGC unit.
4.4.5 The surveyor should verify that each EGC unit is installed in accordance with the
ETM-A and has an SECC as required.
4.4.6 At the discretion of the Administration, the surveyor should have the option of
checking one or all of the identified components, operating values or settings. Where
there is more than one EGC unit, the Administration may, at its discretion, abbreviate
or reduce the extent of the survey on board, however, the entire survey should be
completed for at least one of each type of EGC unit on board provided that it is
expected that the other EGC units perform in the same manner.
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.
4.4.8 Under Scheme A, if a continuous exhaust gas monitoring system is not fitted, it is
recommended that a daily spot check of the exhaust gas quality in terms of
SO2(ppm)/CO2(%) ratio, is used to verify compliance in
conjunction with parameter checks stipulated in paragraph 4.4.7. If a continuous exhaust
gas monitoring system is fitted, only daily spot checks of the parameters listed in
paragraph 4.4.7 would be needed to verify proper operation of the EGC unit.
4.4.9 If the EGC system manufacturer is unable to provide assurance that the
EGC unit will meet the Certified Value or below between surveys, by means of the
verification procedure stipulated in paragraph 4.4.1, or if this requires specialist
equipment or in-depth knowledge, it is recommended that continuous exhaust gas
monitoring of each EGC unit be used, Scheme B, to assure compliance with regulations
14.1 and/or 14.4 of MARPOL Annex VI.
4.4.10 An EGC Record Book should be maintained by the shipowner recording maintenance and
service of the unit including like-for-like replacement. The form of this record should
be submitted by the EGC system manufacturer and approved by the Administration. This EGC
Record Book should be available at surveys as required and may be read in conjunction
with engine-room log-books and other data as necessary to confirm the correction
operation of the EGC unit. Alternatively, this information should be recorded in the
vessel's planned maintenance record system as approved by the Administration.