1. What have we learned in the meantime?
"Exhaust Gas Scrubbers - An 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

2. Content 1)About motivations for installing Scrubbers
2)About legislation(s) and Requirements  
– IMO
– EU sulphur directive
– US EPA VGP
3) Introduction to SAACKE LMB EGC System
4)About Testing & Commissioning
5)Non-100% load design option

3. 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”)

4. Motivations for Scrubbers - PROs
Overview and timeline for IMO Air Pollution Regulations
GLOBAL
ECA
global
(S)ECA
2010
2011
2012
2013
2014
2015
2016
2017
2018
2019
2020
2021
Nox Tier II, global
Nox Tier III, ECA
3.5% S, global
review
0.5% S, global
1%S, (S)ECA
0.1%S, (S)ECA
0.1%S, EU ports

5. Motivations for Scrubbers - PROs
Main driver: Cost benefit

6. Motivations for scrubber -PROs

7. Motivations for Scrubbers - PROs
Other important driver: Greener image

8. 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

9. Emission Control Areas

10. Legislative Requirements
Certification according to IMO MEPC 184(59): Guidelines for Exhaust Gas Cleaning Systems
An Exhaust Gas Cleaning System (EGC) as an alternative method to comply with Regulation and 14.4 of Revised MARPOL Annex VI; Sulphur oxides (SOx) and particulate matter (PM)
Compliance demonstrated on basis of SO2/CO2 ratio as an equivalence to fuel oil sulphur content

11. Legislative Requirements
Fuel oil sulphur limits and corresponding SO2/CO2 ratio:
(EGCS must meet SO2/CO2 ratio values)
Fuel Oil Sulphur Content
Ratio Emission
(% m/m)
SO2 (ppm)/CO2(% 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

12. Legislative Requirements
EU sulphur directives (EC Directive 2012/33/EC amending Council Directive 1999/32/EC)

13. 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
Sulphur limits of Directive 1999/32/EC aligns with IMO rules regarding SECAs  
EGCS are included, testing standard:  
IMO Res. MEPC 184(59)

14. DNV GL approval process on m/t LEVANA

16. 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 and 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, and 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)

17. Introduction to SAACKE LMB EGCS

18. Introduction to SAACKE LMB EGCS

19. Introduction to SAACKE LMB EGCS

20. Introduction to SAACKE LMB EGCS

21. Introduction to SAACKE LMB EGCS

22. Introduction to SAACKE LMB EGCS

23. 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).

24. Testing and commissioning

25. 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
The undersizing of the EGCS may also be possible under Scheme A, provided other arrangements are in place to cover maximum loads. The EGCS should be sized based on maximum fuel oil sulphur content and intended loads
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

26. Many thanks for your kind attention.