INTERNATIONAL MARITIME ORGANIZATION
E
IMO
INTERSESSIONAL MEETING OF THE
BLG WORKING GROUP ON AIR
POLLUTION
2nd session
Agenda item 5
BLG-WGAP 2/5/1
4 October 2007
ENGLISH ONLY
AMENDMENTS TO THE GUIDELINES FOR
ON-BOARD EXHAUST GAS-SOX CLEANING SYSTEMS
Proposed amendments to BLG-WGAP 2/5
Submitted by Euromot
SUMMARY
Executive summary:
This document provides comments and proposals for consideration
for the amendments to the Guidelines for on-board Exhaust Gas-SOx
Cleaning Systems as developed by the Working Group on Air
Pollution at MEPC 56
Action to be taken:
Paragraph 3
Related document:
BLG-WGAP 2/5
1
MEPC 56 instructed the second intersessional Working Group on Air Pollution
(BLG-WGAP 2) to conduct a final review of the proposed amendments to
resolution MEPC.130(53), and, if possible, finalize the amendments for subsequent adoption by
MEPC 57.
2
Euromot has considered BLG-WGAP 2/5 in light of its implementation and found some
issues which should be revisited by BLG-WGAP 2. The proposed amendments are set out in
annex to this document.
Action requested of the Intersessional Meeting of the Working Group
3
The intersessional Meeting is invited to consider the proposed amendments to
BLG-WGAP 2/5 and decide as appropriate.
***
For reasons of economy, this document is printed in a limited number. Delegates are
kindly asked to bring their copies to meetings and not to request additional copies.
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BLG-WGAP 2/5/1
ANNEX
PROPOSED AMENDMENTS TO BLG-WGAP 2/5
1) Section 2.3
Comment:
Incinerators should be excluded as it is mentioned in chapter 2.2.1.
Proposal:
At the end of the sentence: “Fuel oil combustion unit”… add: “, excluding incinerators.”
2) Section 2.3
Comment:
Mentioning and referring to different schemes is not relevant in this chapter as this chapter is
dedicated to definitions.
Proposal:
Delete references to schemes.
3) Section 2.3
Comment:
For the sake of clarity the definitions for the following should be added: SECA, EGC and CEMS.
In chapter 4.4.10 is mentioned “EGC Record Book” and in chapter 9.2.2.1 “ETM Record Book”.
They apparently are the same thing.
Proposal:
Add definitions for SECA, EGC and CEMS. Improve the chapter structure and content to be
more clear. Harmonize the terminology in the whole document to correspond the definitions.
4) Section 3
Comment:
This chapter is partly discussing the same issue as covered by Wash Water Discharge Criteria.
Proposal:
Delete the sentence: “In locating discharge outlet of washwater used in the EGCS unit, due
consideration should be given to the location of the ship's sea water inlet and other implications
of the acidic nature of such water.” from this chapter.
5) Section 4.1.2.1
Comment:
It is not relevant to generally determine the maximum fuel sulphur content for achieving the
certified limit value of EGC unit. 4.5% m/m sulphur fuel oil is very rarely available and it would
be over-dimensioning to use this as a design criteria. The fuel sulphur content for the EGC unit
approved should be specified by the manufacturer and documented in the SCP and ETM.
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BLG-WGAP 2/5/1
ANNEX
Page 2
Proposal:
Replace the wording “… oils up to 4.5% m/m sulphur…” with “oil sulphur content specified in
the ETM…”.
6) Section 4.1.2.2
Comment:
It is not relevant to give exact test fuel sulphur contents as the variation of fuel sulphur content is
wide depending on purchasing location. Purchasing special fuel oils with exact sulphur contents
for EGC testing may cause unnecessary burden.
Proposal:
Replace the sentence: “The minimum sulphur content…” with “The sulphur content of the fuel
oil used in one test should be in range of 1.5-2.5% m/m”.
Replace the sentence: “The other fuel oil…” with “The other fuel oil should have sulphur content
of at least 3.0% m/m.”
7) Section 4.1.2.2
Comment:
Same as in 4.1.2.1
Proposal:
Modify the end of the last sentence to:
“…when used with a fuel oil with a fuel sulphur content specified in the ETM.”
8) Section 4.2.2.1 (iii)
Comment:
The alkalinity and pH are different things and should be separated for the sake of clarity.
Proposal:
Modify the end of the sentence to: “…alkalinity or pH.”
9) Section 4.4.7
Comment:
Automatic recording of the parameters is not reasonable for type approved and certified EGC
units. For example EIAPP certified diesel engines do not require recording of any parameters.
No recording should be required from unit approved EGC units either.
Proposal:
Delete chapter 4.4.7.
10) Section 4.4.8
Comment:
For type approved and certified EGC units the daily spot checking should not be required.
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BLG-WGAP 2/5/1
ANNEX
Page 3
Proposal:
Delete the first sentence and modify the rest of the chapter to:
“If a continuous exhaust gas monitoring system is fitted, the following parameters should be
checked daily to verify proper operation of the EGC unit: wash water pressure and flow rate at
the EGC unit’s inlet connection, pH of washwater at the EGC unit’s inlet and outlet connections,
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.”
11) Section 5.3.1 (the first)
Comment:
The SCP is discussed in chapter 9.1.1, so this chapter is not necessary.
Proposal:
Delete the first chapter 5.3.1.
12) Section 5.5.2
Comment:
See comment for 4.4.7 and 4.4.8.
Proposal:
Delete chapter 5.5.2.
13) Section 8.1
Comment:
The sentence is unclear.
Proposal:
Modify the sentence to: “An OMM should be prepared to cover the EGC unit for each item of
fuel oil combustion equipment, which should be identified, for which compliance is to be
demonstrated.”
14) Section 9.1.1
Proposal:
Delete “[of MARPOL Annex VI]” at the end of last sentence.
15) Section 9.1.3
Comment:
See comments for 4.4.7, 4.4.8 and 5.5.2.
Proposal:
Modify the sentence to: “Under Scheme A, the ETM should present how the parameters in
paragraph 4.4.8 are maintained within the manufacturer’s recommended specifications.
Under Scheme B, this would be demonstrated using daily spot checks of key parameters.”
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BLG-WGAP 2/5/1
ANNEX
Page 4
16) Section 9.1.4
Comment:
See comments for 4.4.7, 4.4.8, 5.5.2 and 9.1.3.
Proposal:
Modify the last sentence to “Under Scheme A, the SCP would refer to the ETM, stating how this
would be demonstrated using exhaust gas emission spot checks.”.
17) Section 9.2.2.1 / 9.2.2.2 / 9.2.2.3
Comment:
Chapter numberings is not correct.
Proposal:
Correct chapter numberings.
18) Section 9.2.2.3
Comment:
Continuous recording of parameters from type approved and certified ECG unit is not necessary.
See comment for 4.4.7.
Proposal:
Delete chapter 9.2.2.3.
____________
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