"Exhaust Gas Scrubbers Abatement System as an Alternative under IMO MARPOL Annex VI'' What have we learned in the meantime? Prepared by: Ljubomir Markulin, Naval Architect SAACKE Marine Systems - Zagreb, Croatia
Content 1)About motivations for installing Scrubbers - PROs & CONs 2)About legislation(s) and Requirements – IMO – EU sulphur directive – US EPA VGP – CARB 3) Introduction to SAACKE LMB EGC System 4)About Testing & Commissioning 5)About non-100% load design option
Motivations for Scrubbers - PROs Operational air emissions by ships: NOx - Nitrogen Oxides (MARPOL Annex VI, Reg 13) SOx - Sulphur Oxides (MARPOL Annex VI, Reg 14) PM - Particulate Matter (ECA North America - MARPOL Annex VI, Reg 14) CO2 - Greenhouse Gas Emissions - GHG (MARPOL Annex VI, Chpt 4 - “Regulations on energy efficiency for ships ” )
Motivations for Scrubbers - PROs • Overview and timeline for IMO Air Pollution Regulations GLOBAL Nox Tier II, global ECA Nox Tier III, ECA global 3.5% S, global review 0.5% S, global 1%S, (S)ECA 0.1%S, (S)ECA (S)ECA 0.1%S, EU ports 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021
Motivations for Scrubbers - PROs Main driver: Cost benefit 1500 300% MGO - 0.1% - USD per ton - Rotterdam 1400 MDO - max 0.2% - USD per ton - Rotterdam 280% IFO 380 - max. 4.5% - USD per ton - Rotterdam 1300 260% Crude oil (Dated Brent) - USD per barrel 1200 240% Price difference IFO 380 vs MGO in % (right axis) 1100 220% Price difference IFO 380 vs MGO in % - moving average for 52 weeks (right axis) 1000 200% 900 180% 800 160% USD 700 140% 600 120% 500 100% 400 80% 300 60% 200 40% 100 20% 0 0% 1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009
Motivations for scrubber -PROs CAPEX and OPEX for typical 10 MW EGCS hybrid type 20 100% ECA 60% ECA 15 20% ECA Cost savings Mio $ 0% ECA 10 5 0 -5 2016 2017 2018 2019 2020
Motivations for Scrubbers - PROs Other important driver: Greener image
Motivations for scrubber - CONs What’s so special about scrubbers? • Marine engineers do not like them - supervision and maintenance of sofisticated machinery scrubbing equipment instead of fuel change over (HFO to MGO) • The owners do not want them - CAPEX and OPEX relatively high, ROI long in case the ship is not trading in ECA, of hire of the ship during installation and testing • The „environmentalists” do not want them - there are contaminated effluent waters (pH, Turbidity, PAH); preferred solution is the fuel change over Lot of people do not know what the scrubber really is. Nevertheless, many have strong opinion about it. Maybe, because they have heard: • The interpretation of legislation is still uncertain • The technology is still not mature • The cost/benefit is still uncertain
Emission Control Areas
Legislative Requirements Certification according to IMO MEPC 184(59): • 2009 Guidelines for Exhaust Gas Cleaning Systems ƒ An Exhaust Gas Cleaning System (EGC) as an alternative method to comply with Regulation 14.1. and 14.4 of Revised MARPOL Annex VI; Sulphur oxides (SOx) and particulate matter (PM) ƒ Compliance demonstrated on basis of SO2/CO2 ratio as an equivalence to fuel oil sulphur content
Legislative Requirements Fuel oil sulphur limits and corresponding SO2/CO2 ratio: ( EGCS must meet SO2/CO2 ratio values) Fuel Oil Sulphur Ratio Emission Content (% m/m) SO 2 (ppm)/CO 2 (% v/v) 4.5 195.0 3.5 151.7 1.5 65.0 1.0 43.3 0.5 21.7 0.1 4.30
Legislative Requirements • EU sulphur directives ( EC Directive 2012/33/EC amending Council Directive 1999/32/EC) Maximum sulphur content in marine fuel Marine fuels: 3.50% m/m (except ships using closed loop EGCS) Gas oil: 0.10% m/m Sulphur content within ECA 1.00 % m/m until 31.12.2014 0.10 % m/m from 01.01.2015 Within territorial seas 3.50 % m/m as from 18.06.2014 0.50 % m/m from 01.01.2020 Sulphur content for passenger ships operating on regular Sulphur content of marine fuels used by ships at services to or from any Union Port shall not exceed 1.50 % berth in Union ports m/m until 01.01.2020 0.1% m/m Does not apply if: ships are at berth less than two hours ship switches off all engines and uses shore-side electricity
Legislative Requirements • EU sulphur directives (EC Directive 2012/33/EC amending Council Directive 1999/32/EC) Emission abatement methods are allowed if they have a MED approval Approval according to Article 4d(1) Reference to directive 96/98/EC (Marine Equipment Directive) Direct reference to IMO Res.MEPC184(59) is made Additionally quality systems have to be checked (Modules D, E, F, G) Due to complexity of the scrubber system Module G is the most practical. Sulphur limits of Directive 1999/32/EC aligns with IMO rules regarding SECAs. EGCS is recognised as equivalent method to HFO/MGO fuel change over. Testing standard to be applied for the certification: IMO Res. MEPC 184(59)
DNV GL approval process on m/t LEVANA
Legislative Requirements US EPA VGP (Vessel General Permit) - additional requirements to MEPC 184(59) • pH (Washwater alkalinity/acidity) Limit : ≥ 6.0 pH units at ship´s overboard or <2 pH between inlet and outlet. • In addition to the continuous monitoring of pH, PAH and turbidity the vessel owner/operators must collect and analyse two samples in the first year of permit: Nitrate-Nitrite and dissolved Total Metals , including, Arsenic, Cadmium, Chromium, Copper, Lead, Nickel, Selenium, Thallium, Vanadium, and Zinc. • After the first year, samples must be collected at least once per calendar year for inlet water (for background), water after the scrubber (but before any treatment system) and discharge water. This may be collected as part of the vessel’s annual survey as appropriate. Records of the sampling and testing results must be retained onboard for a period of 3 years in the vessel’s recordkeeping documentation. • Discharge of exhaust gas scrubber washwater into Connecticut waters is prohibited (no open-loop operation allowed)
Legislative Requirements • California Air Resources Board (CARB) Californian waters: Part of North American ECA - California OGV Fuel Regulation contains no provisions for use alternative emission control technologies (scrubbers) to achieve 0.1% Sulphur level - Ships operating in Californian waters on and after 1 January 2015 must comply with both the California OGV Fuel Regulation and the MARPOL ECA requirements. - CARB Marine Notice 2014-1 provides guidance that will allow vessels to comply with California OGV Fuel Regulation when they are complying with North American ECA MARPOL regulation (using alternative emission control technologies or non-distillate low sulphur fuels)
Introduction to SAACKE LMB EGCS
Introduction to SAACKE LMB EGCS
Introduction to SAACKE LMB EGCS •
Introduction to SAACKE LMB EGCS
Introduction to SAACKE LMB EGCS
Introduction to SAACKE LMB EGCS
Testing and commissioning During commissioning of scrubber systems on vessels in trade the scrubber has to be tested with non-compliant fuel within ECA. Scrubbers are not considered as “new technology” acc. to MARPOL Annex VI, Regulation 3, EU Directive 2005/33/EC, Article 4c, and EU Directive 2012/33/EU, Article 4e. Solution: issuance of Interim conditional IAPP Certificate, to be accepted by administration of waters where the vessel operates (Flag Administration). Reference is made to agreement between DNVGL and Germany, accepted by Gibraltar and Sweden, UK and Netherlands pending (Letter of No Objection).
Testing and commissioning
Non 100% Design Capacity of Scrubbers • Scheme B: The SO2/CO2 ratio alone demonstrates compliance irrespective of the number of main and auxiliary engines and irrespective of load • The size of the scrubber does not need to have a design capacity to cover a full load at all times • However, the size of the exhaust duct needs to be sized to reflect the number of engines that will be operated simultaneously • In any case the SOx Emissions Compliance Plan ( SECP ) has to state that the cleaning system is only designed for part loads AND a procedure is to be given how to comply with the fuel oil sulphur limits in cases when the scrubber is running at higher loads, e.g. stating that LSFO / MGO should be used in these cases
Many thanks for your kind attention.
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