INTERNATIONAL MARITIME ORGANIZATION
E
IMO
INTERSESSIONAL MEETING OF THE
BLG WORKING GROUP ON AIR
POLLUTION
2nd session
Agenda item 5
BLG-WGAP 2/5/2
5 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 Finland
SUMMARY
Executive summary:
This document provides comments and proposals for consideration
for finalizing 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 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
Finland 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 can be found in
the 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.
I:\BLG\WGAP\2\5-2.doc
BLG-WGAP 2/5/2
ANNEX
PROPOSED AMENDMENTS TO BLG-WGAP 2/5
#
1
2
Section
1.1
2.2.1
3
2.3
4
2.3
5
6
2.3
3
Proposed amendment
Comment:
The last part of the last sentence should be modified, as it may
erroneously give the reader the impression that there are some other
guidelines.
Proposal:
“…by the Administration taking into account these guidelines.”
Comment:
There are several reasons why scrubbers will be operated even outside
SECAs. It may be more practical to let scrubbers run continuously than
switching them on and off, and there may be reasons to reduce
SOx-emissions also outside SECAs. In such areas these guidelines are not
relevant for the SOx emissions, but for wash water they are. The text
should be modified accordingly.
Proposal:
Add new sentence at the end: “The wash water regulations also apply
outside SECAs.”
Proposal:
At the end of the definition of “Fuel oil combustion unit”, add:
“, except incinerators.”
Comment:
Until now, the exact use of SCC and ETM in different schemes (A and B)
is not clear.
Proposal:
To avoid contradictions, delete references to different schemes in this
chapter.
Comment:
In 4.4.10 there is something called an “EGC Record Book”.
In 9.2.2.1 there is something called an “ETM Record Book”.
These terms should be harmonized.
Proposal:
Call it “EGC Record Book” or “EGCS Record Book”, define it in 2.3,
and use it consistently.
Comment:
There is a certain overlap with safety guidance provided under item #1
(pH) in document BLG-WGAP 2/4 (draft wash water criteria).
Proposal:
1. At the end, insert: “In all operating conditions the pH shall be
maintained at a level that avoids damage to the vessel’s antifouling
system, the propeller, rudder and other components that may be
vulnerable to acidic discharges, potentially causing accelerated corrosion
of critical metal components.”, and
2. Delete the corresponding text in BLG-WGAP 2/4 (items 1.B.2, 1.B.3
and footnote 1.
I:\BLG\WGAP\2\5-2.doc
BLG-WGAP 2/5/2
ANNEX
Page 2
7
8
9
10
11
12
4.1.2.1
4.1.2.2
4.1.2.2
4.1.3.1
4.4
5.3.1
Comment:
The requirement to certify each unit as capable of meeting a fuel sulphur
content of 4.5% is exaggerated in many cases. The installation can be
made more practical if designed for realistic values. To avoid an
over-dimensioning of plant physical sizes, pumping energy etc regulations
should permit selection of a suitable figure for each case. In such cases
the freedom for the ship to select bunker will be limited. This limitation
will be documented in the SCP and the ETM (under Scheme A). In case
of Scheme B (for which this paragraph is not relevant), this freedom is
already inherent, and compliance is demonstrated by Continuous
Emission Monitoring System records.
Proposal:
Replace the wording “…4.5% m/m sulphur…” with “a fuel sulphur content
specified by the manufacturer in the ETM”
Comment:
As pointed out in BLG-WGAP 1/2/12 by Finland and Norway and
MEPC 56/4/4 by Euromot, the proposed test fuel may be problematic in
some cases.
Proposal:
The fourth and fifth sentences are replaced with: “The sulphur content of
the fuel oil used in one test should be 2.0 plus/minus 0.5%. The other fuel
oil should have a sulphur content of at least 3.0%.”
Comment:
Please see explanation under 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.”
Comment:
The reference to 4.2.1.1 is probably a misprint, and actually not even
relevant. The purpose of the wording is to say that unnecessary tests can
be avoided.
Proposal:
Replace “…in accordance with 4.2.1.1” with “of”.
Comment:
The title of this chapter should refer not only to emissions, but also to
discharge of wash water. The easiest text modification would be to delete
the last three words.
Proposal:
Call this title: “4.4 Onboard procedures for demonstrating compliance”
Comment:
There are two chapters with the same number.
Proposal:
Update numbering.
I:\BLG\WGAP\2\5-2.doc
BLG-WGAP 2/5/2
ANNEX
Page 3
13
14
15
16
5.3.1
5.4.1
5.5.2
6.2
17
8.1
18
8.1
19
8.1
20
8.2
21
9.1.1
22
9.1.3
23
9.1.3
24
9.1.4
Comment:
The first chapter 5.3.1 stipulates an SCP. This requirement is repeatedly
mentioned in this document, e.g., in 9.1.1, which is appropriate for this
purpose.
Proposal:
Delete (the first) chapter 5.3.1.
Comment:
Chapter 5.3.1 refers to 6.2 and 6.15, and nothing in between.
Proposal:
Review the application of chapters 6.3 to 6.14 in case of Scheme A and B.
Comment:
Under Scheme B, the normal values of these parameters are not
documented anywhere, as there is no ETM. Therefore daily spot checks of
these parameters are not really meaningful, as normal ranges are not
documented.
Proposal:
Delete 5.5.2.
Comment:
In MEPC 56, comment #6 of BLG-WGAP 1/2/12 was approved.
The exact wording should be inserted accurately to reflect this decision.
Proposal:
1. In the second sentence, after CO2, insert: “…and O2…”.
2. Delete the last sentence.
Proposal:
After “…to cover…” insert: “…the EGC unit for…”
Proposal:
Delete the last three words of this sentence as useless and misleading.
Proposal:
Add a new sentence: “The OMM can also be a part of the ETM”.
Proposal:
After “…emission…” insert “…and wash water…”
Proposal:
After “…Administration…” insert full stop and delete the rest of the
sentence as useless.
Proposal:
After “…the SCP should…” insert “refer to the ETM, which should…”.
Proposal:
Delete the last sentence if decided to delete 5.5.2.
Comment:
This chapter should be harmonized with the proposed modifications
of 4.4.8.
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.”.
I:\BLG\WGAP\2\5-2.doc
BLG-WGAP 2/5/2
ANNEX
Page 4
25
26
27
28
29
30
31
9.2
9.2.1
9.2.2.1
9.2.2.3
9.2.2.1
10.1
General
Comment:
The text for Scheme A and B can be made identical.
Proposal:
Delete the division into Scheme A and B. Update numbering of
subchapters with 4 digits by deleting one digit.
Comment:
There are mistakes in chapter numbering.
Proposal:
Update numbering of subchapters with 4 digits for consistency.
Comment:
This comment refers to the first 9.2.2.1 (should read 9.2.1.1).
Proposal:
Delete the end of the first sentence “…as specified under Scheme A.”
Comment:
To avoid inconsistencies, long lists of parameters listed elsewhere should
not be repeated here. Simplify this text by replacing it with a shorter
sentence with the same substance.
Proposal:
“Required parameters should be monitored and recorded as required
while within a SECA in order to demonstrate compliance.”
Comment:
This comment refers to the second 9.2.2.1.
Proposal:
Delete this chapter.
Comment:
Compliance with the nitrate and additive requirement of BLG-WGAP 2/4
should obviously be documented in the ETM, apparently equally for
Scheme A and B. Consequently all scrubbers need an ETM, and therefore
also a SCC. The conclusion of this is that the document structure for
Scheme A and B is the same, but the content will be somewhat different.
Proposal:
Update the guideline in all respects accordingly.
Proposal:
Continue to improve the structure of the document. Correct discrepancies
between table of content and text.
____________
I:\BLG\WGAP\2\5-2.doc