2020 Sulphur cap And Future GHG reduction - Outcome of MEPC 74: Consistent implementation of the global sulphur cap Wei Gao, DNVGL RGC Pre-contact ...
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MARITIME 2020 Sulphur cap And Future GHG reduction Outcome of MEPC 74: Consistent implementation of the global sulphur cap Wei Gao, DNVGL RGC Pre-contact and Technical Support 22 May 2019 1 DNV GL © 22 May 2019 SAFER, SMARTER, GREENER
Agenda Introduction Outcome MEPC 74 Class’ perspective: Safety+reliability Project management and DNV GL project organization How DNV GL can support Future GHG reduction 2 DNV GL © 22 May 2019
Introduction
A paradigm shift in marine fuels is on our door step with the introduction of
global sulphur cap of 0.50% Sulphur in 2020
0.5% limit in Taiwan ports, 2019
New Compliant Fuels?
HFO + Scrubber MGO / MDO Alternative Fuels
(0.5%S)
DNV GL © 22 May 2019
Introduction
How to get prepared – what if…?
1. Ship Implementation Plan
(MEPC.1/Circ.878) is intended as a
guidance and tool for ship operators
to prepare for complying with the
0.50% sulphur limit in 2020. The plan
is not mandatory and is not
subject to endorsement by the flag
or a Recognized Organization.
• Risk assessment
• Structural modifications and tank cleaning (if needed)
• Fuel oil capacity
• Procurement of compliant fuel
• Fuel oil changeover plan
• Documentation and reporting
2. Fuel oil non-availability report
(FONAR) intended to be used by ship
operators in case they are not able to
procure compliant fuel. DNV GL Ship Implementation Plan generator
https://store.veracity.com/7ba6bcf0-77ef-44bf-adf8-54d8cbbf4a72
4 DNV GL © 22 May 2019
Introduction
Local requirements: China
▪ From 1 January 2019, all ships entering China’s coastal waters
must use fuel with a maximum sulphur content of 0.5% m/m.
▪ SOx Scrubbers are considered as alternative solution, however:
• The discharge of washwater generated by exhaust gas
cleaning systems (scrubbers) must meet the requirements of
IMO regulations.
• It is prohibited to discharge washwater generated by open-
loop scrubbers within the inland emission control areas,
ports of coastal emission control areas and Bohai Bay water
areas (marked red in map).
More info (in Chinese only) here:
http://www.msa.gov.cn/html/xinxichaxungongkai/gkml/wgfw/tzggwgfw/20181229
/D383773A-FC2C-4D64-976D-1B7E8CDC13AB.html
A ban of wash water of the open loop scrubbers in the complete control area
(light green in map) will be announced in due course!
5 DNV GL © 22 May 2019 *with the exception that during manoeuvring and transit, the maximum
difference between inlet and outlet of 2.0 pH units is allowed.
Introduction
Open loop or not open loop?
No wash water discharge in:
▪ Connecticut, USA
Open Loop ban:
▪ Singapore
▪ Fujairah
▪ Belgium
▪ Germany (limited to some ports)
▪ More in info paper by ICS
No stricter requirements have been posed by IMO for international waters
▪ MEPC74 approved, in principle, a new output on "Evaluation and
harmonization of rules and guidance on the discharge of liquid effluents from
EGCS into waters, including conditions and areas“
▪ GESAMP is entitled to convey a study and submit the report to PPR7 (2020)
MEPC 74: “Due consideration should be given to early movers who had fitted their vessels with EGCS to avoid
penalizing them”
6 DNV GL © 22 May 2019 *with the exception that during manoeuvring and transit, the maximum
difference between inlet and outlet of 2.0 pH units is allowed.
Introduction
Confirmed orders (all classes): Data from DNV GL “AFI” Portal
Annual number of confirmed scrubber system installations
2500 ▪ There are more than 3000 ships with
installed or firmly planned scrubber systems
2000 installations (NB+Conversion)
404
Retrofit ▪ Optimistic predictions estimate max. 4000
1500
Newbulding
installations totally (all classes)
▪ IMO GESAMP study estimates a max. annual
1000 docking capacity of 3000 ships (MEPC 70/INF.6)
1679
▪ The “scrubber wave” is now on, with 2100
500
confirmed retrofit installation in 2019
127
172
(all classes)
33 203 232
10
59 105 25
45 52 23
0 0
1 0
3 1
4 4
5 9
10 22 29 3
4 0
1
2008 2009 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 ▪ Peak of installations will be in June/July 2019
“on an average 5.8 scrubber confirmed conversions per day for all classes” in 2019
7 DNV GL © 22 May 2019
Introduction
Majority of installations are of Open type, Bulk carriers leading segment
Scrubber Type Segment distribution
67 37 19 41
65 36 Bulk carriers 70
Container ships 77
Oil/Chemical tankers
125
540
Open
Crude oil tankers
265
1129
Cruise ships
Hybrid
Ro-Ro cargo ships
Gas tankers
Closed 414
General cargo ships
RoPax
Unknown Car Carriers
2625 Car/Passenger ferries
470
Other Activities
588
Fishing vessels
▪ Despite current washwater discussion majority of installations are ▪ Cruise and RoPax were initially the largest segments
Open type
▪ Now bulk, containers and tankers are the largest
segments
8 DNV GL © 22 May 2019
Introduction
More info on DNV GL Alternative Fuels Insight platform
▪ Statistics
https://afi.dnvgl.com/ ▪ Live AIS data of ships with Scrubbers, LNG as fuel, Battery power
9 DNV GL © 22 May 2019
Agenda Introduction Outcome MEPC 74 Class’ perspective: Safety+reliability Project management and DNV GL project organization How DNV GL can support Future GHG reduction 10 DNV GL © 22 May 2019
Outcome MEPC74 Guidelines approved at MEPC 74 MEPC 74 approved several guidelines to ensure a consistent implementation of the 0.50% sulphur limits for fuel oils: ▪ Resolution MEPC.320(74): Guidelines for consistent implementation of the 0.50% sulphur limit (including the Fuel Oil non-Availability Report): ▪ Resolution MEPC.321(74): Guidelines for port state control (including how to handle non- availability claims) ▪ MEPC.1/Circ.882: Guidance for port state control on contingency measures for addressing non- compliant fuel oil ▪ MEPC.1/Circ.883: Best Practice for member and coastal states ▪ MEPC.1/Circ.864/Rev.1: Guidelines for on board sampling for the verification of the sulphur content of the fuel oil used on board ships ▪ MEPC.1/Circ.884: Guidelines in case of failure and recommended actions for Exhaust Gas Cleaning Systems (EGCS) 11 DNV GL © 22 May 2019
Outcome MEPC74
Guidelines for consistent implementation of the 0.50% sulphur limit
The purpose of these Guidelines is to ensure consistent implementation of the 0.50% sulphur limit
under MARPOL Annex VI. These Guidelines are intended for use by Administrations, port States,
shipowners, shipbuilders and fuel oil suppliers:
▪ Ship implementation planning for 2020 (SIP)
▪ Impact on fuel and machinery systems:
– Distillate fuels: Low viscosity may cause internal leakages in diesel engines, boilers and pumps
– Distillate fuel with FAME content: There are various technical challenges associated with use of
fuel having FAME content, e.g. potential oxidation of biodiesel, its biodegradable nature etc.
with adverse implications, limitations in storage life etc. It also needs to be tested for stability.
– Residual fuels: Unstable fuels can separate on their own and incompatible ones can do so
when mixed in a single bunker tank, forming sludge that can block filters and ultimately cause
engine failures. It is recommended that ships have a commingling procedure. The procedure
should primarily aim to ensure new bunkers are loaded into empty tanks to the extent possible
▪ Fuel oil non-availability (FONAR)
12 DNV GL © 22 May 2019Outcome MEPC74
Guidelines for port state control
This document is intended to provide basic guidance on the conduct of port State control
inspections for compliance with MARPOL Annex VI and afford consistency in the conduct of these
inspections, the recognition of deficiencies and the application of control procedures.
▪ Control measures by port States
– The port State should conduct initial inspections based on documents and other possible materials, including remote
sensing and portable devices
– Fuel oil sample analysis: When the port State identifies clear grounds of suspected non-compliance of a ship based on
initial inspections, the port State may require samples of fuel oils to be analysed. The samples to be analysed may be
either the representative samples provided with BDN in accordance with regulation 18.8.2, MARPOL delivered samples or
samples from designated sampling points in accordance with the 2019 Guidelines for on board sampling for the
verification of the sulphur content of the fuel oil used on board ships (MEPC.1/Circ.864/Rev.1) (in-use fuel oil samples) or
other samples obtained by the port State.
– Inspection on ships equipped with Scrubbers: In the case where an EGCS is not in compliance with the relevant
requirements for other than transitory periods and isolated spikes in the recorded output, the master or officer in charge
may have documented that through a Notification to the ship's flag Administration with copies to the competent authority
of the relevant port of destination, and present those corrective actions taken in order to rectify the situation in
accordance with the guidance given in the EGCS Technical Manual.
13 DNV GL © 22 May 2019Outcome MEPC74 Guidance for port state control on contingency measures for addressing non- compliant fuel oil In the case of non-compliant fuel oil, communication between the ship and the port State should occur. The ship and the port State should consider the following as possible contingency measures: ▪ actions predetermined in the Ship implementation plan (SIP), if available, for consistent implementation of the 0.50% sulphur limit under MARPOL Annex VI (MEPC.1/Circ.878) ▪ discharging non-compliant fuel oil to another ship to be carried as cargo or to an appropriate shipboard or land-based facility, if practicable and available ▪ managing the non-compliant fuel oil in accordance with a method acceptable to the port State ▪ operational actions, such as modifying sailing or bunkering schedules and/or retention of non- compliant fuel oil on board the ship. The port State and the ship should consider any safety issues and avoid possible undue delays ▪ Having considered all of the options above, the non-compliant fuel oil may be discharged to the port or retained on board, as acceptable to the port State 14 DNV GL © 22 May 2019
Outcome MEPC74 Best Practice for member and coastal states These best practices are intended to assist Member States in carrying out their responsibilities under MARPOL Annex VI, to ensure effective implementation and enforcement of statutory requirements of that Annex. ▪ Member States/coastal States should promote the availability of fuel oils which comply with MARPOL Annex VI and require suppliers under their jurisdiction to provide fuel oils that comply with the requirements of regulation 14 and regulation 18.3 of MARPOL Annex VI ▪ Any measures to promote the availability of fuel oils in ports should not lead to distortion of competition. It should be left to individual fuel oil suppliers to make investment decisions based on the market opportunities they see ▪ Member States/coastal States should provide timely information on upcoming regulations to suppliers under their jurisdiction, including revisions of the information required on the bunker delivery note ▪ Member States or other relevant authorities desiring to do so may decide to establish or promote a licensing scheme for bunker suppliers 15 DNV GL © 22 May 2019
Outcome MEPC74 Guidelines for on board sampling for the verification of the sulphur content of the fuel oil used on board ships The objective of these Guidelines is to establish an agreed method for sampling to enable effective control and enforcement of liquid fuel oil being used on board ships under the provisions of MARPOL Annex VI. ▪ New definitions under Regulation 2 of MARPOL Annex VI: – In-use sample means the sample of fuel oil in use on a ship – On board sample means the sample of fuel oil intended to be used or carried for use on board that ship ▪ The in-use representative sample or samples should be obtained from a designated sampling point or points. The number and location of designated fuel oil sampling points should be confirmed by the Administration following consideration of possible fuel oil cross-contamination and service tank arrangements. ▪ The installation of the sampling point will be endorsed in an updated supplement to the IAPP: 16 DNV GL © 22 May 2019
Outcome MEPC74
Guidelines in case of failure and recommended actions for Exhaust Gas Cleaning
Systems
This document addresses countermeasures and actions to be taken in case of failures of EGCS and its
monitoring systems. Ships are not expected to deviate from a voyage to repair the EGCS, but if
compliant fuel are carried on-board it must shift to this fuel. A proposed course of action to bunker
compliant fuel or carry our repair work must be agreed with the relevant authorities.
▪ An Exhaust Gas Cleaning System (EGCS) malfunction is any condition that leads to an emission exceedance, with the exception of
the short-term temporary emission exceedance cases or an interim indication of ongoing compliance in the case of sensor failure
– Short-term temporary emission exceedance: A short-term temporary emission exceedance is an exceedance of the
applicable Emissions Ratio that may occur due to the EGCS dynamic response when there is a sudden change in the exhaust gas
flow rate to the EGCS.
– Interim indication of ongoing compliance in the case of sensor failure: If a malfunction occurs in the instrumentation for
the monitoring of Emission Ratio or discharge water (pH, PAH, Turbidity), the ship should keep records of interim indication for
demonstrating compliance (e.g. flow rates, pressures, …)
▪ Any EGCS malfunction that lasts more than one hour or repetitive malfunctions (of less than one hour) should be reported
to the flag and port Stateʹs Administration along with an explanation of the steps the ship operator is taking to address the
failure.
▪ At their discretion, the flag and port State's Administration could take such information and other relevant circumstances into
account to determine the appropriate action to take in the case of an EGCS malfunction, including not taking action.
17 DNV GL © 22 May 2019Agenda Introduction Outcome MEPC 74 Class’ perspective: Safety+reliability Project management and DNV GL project organization How DNV GL can support Future GHG reduction 18 DNV GL © 22 May 2019
Class’ perspective: Safety+reliability Corrosion 19 DNV GL © 22 May 2019
Class’ perspective: Safety+reliability Flooding 20 DNV GL © 22 May 2019
Class’ perspective: Safety+reliability
CEMS in bypass
Analyser in Bypass:
Design sketch of Continuous Emission
How to verify Monitoring Device (CEMS):
that exhaust
flow in bypass
represents
exhaust flow in
main exhaust
pipe?
21 DNV GL © 22 May 2019Class’ perspective: Safety+reliability
NaOH crystallization
22 DNV GL © 22 May 2019Class’ perspective: Safety+reliability Material selection of packed beds 23 DNV GL © 22 May 2019
Class’ perspective: Safety+reliability Data recording 24 DNV GL © 22 May 2019
Agenda Introduction Outcome MEPC 74 Class’ perspective: Safety+reliability Project management and DNV GL project organization How DNV GL can support Future GHG reduction 25 DNV GL © 22 May 2019
Project management and DNV GL project organization
Installing one scrubber in 1,5 year is easy, installing 30 to 100 scrubbers in 1,5 year is
difficult
Stakeholder mapping: 11
Example Technology
Sister series Ships Design house Class Yard
suppliers
32 ships, 4 sister series
Series A 8 Scrubber 1 Design House 1 Class 1 Yard 1 and 2
Series B 8 Scrubber 2 Design House 2 Class 2 Yard 2 and 3
Series C 8 Scrubber 1 Design House 1 Class 1 Yard 1 and 3
Series D 8 Scrubber 2 Design House 2 Class 3 Yard 1 and 4
Sum 32 2 2 3 4
Project processes: 392
Technical specifications 4
Basic design 4
Plan approval 32 32
Detailed design 32
A relatively small scrubber Construction drawings 32
retrofit project may require close Planning and purchasing 32 32
follow up of 11 stakeholders and Logistic 32 32
management of 392 individual Installation 32
Commissioning 32 32 32
project processes
Sum 100 36 64 192
26 DNV GL © 22 May 2019Project management and DNV GL project organization
Key processes in a scrubber retrofit program
Key processes: Key processes:
• Establish business case • Align installation plan with dry-docking schedule • Risk management
• Complete technical feasibility study • Change order management • Update SMS and PMS
Contract(s) Program
• Evaluate & select supplier(s) • Process tracking, monitoring and reporting • Establish inspection, test plan
signed & sign off protocols finished
1 – 3 months 1 – 3 years
Business case Program management
Basic design Detailed design
complete complete
Ready for dry-
1 – 3 months 2 - 4 months dock retrofit
Basic design Detailed design
Installation Operationally
Key processes: Key processes: 1 – 3 months complete ready
• Define clear scope • Ensure design quality sufficient
to support procurement &
Planning &
• Identify operational impacts procurement
planning 2 – 6 weeks ~ 2 week
• Identify differences between Key processes:
sister ships
• Develop installation Installation Commissioning
(sequencing) strategy • Develop installation plan Key processes: Key processes:
• Verify backpressure, stability,
• Follow up class approval • Monitor purchasing and • Forecast & progress • Complete MARPOL &
pH compliance
process and drawing status logistic plan reports available to PM performance test
• Manage owner supply • On-site quality control • Make ship operationally ready
27 DNV GL © 22 May 2019Project management and DNV GL project organization
Approval Documents: Who is responsible for what?
▪ Scrubber maker:
• MARPOL Documents
• MAPROL test plan
• Control&Monitoring (PC needed)
• Pumps (PC needed)
MED for Scrubber ▪ Shipyard/designer (integration into ship):
(Governed By Pt.4 Ch.6 Sec.8 ):
• Structual (foundations)
• Tonnage
Control&Monitoring
• Piping
• Electrical
• External/Internal communication
• Stability and watertight integrity
• Load line
• Fire safety
28 DNV GL © 22 May 2019Agenda Introduction Outcome MEPC 74 Class’ perspective: Safety+reliability Project management and DNV GL project organization How DNV GL can support Future GHG reduction 29 DNV GL © 22 May 2019
How DNV GL can support
DNV GL classification – Supporting the low sulphur future
Part 1 Part 2 Part 3 Part 4 Part 5 Part 6 Part 7
General Materials and Hull System and Ship types Additional class Fleet in
regulations welding components notations Service
▪ DNV GL rules and class notations for
– CLEAN and CLEAN DESIGN Notation
– LNG READY Notation
– ECA-Sox
– SCRUBBER READY Notation
– Emission Reduction (ER) for Scrubber and/or EGR and/or SCR installed.
– Published July 2018
30 DNV GL © 22 May 2019How DNV GL can support
DNVGL SOx Scrubber financial calculator
DNV GL © 31 22 May 2019How DNV GL can support
Risk control for Control and Monitoring System
How to reduce risks related to commissioning and automation?
Hardware-In-Loop
▪ When performing HIL, the control
system is isolated from the real system
and instead put into a laboratory.
▪ Necessary actuators, dynamics and
sensors are simulated to fool the
control system. The control system will
believe it is controlling the real thing,
instead it is controlling a set of virtual
machines.
32 DNV GL © 22 May 2019How DNV GL can support
Advisory Services for SOx-Scrubber: CFD Washwater
▪ pH > 6.5 at more than 4 m from the discharge point, for both max and min
discharge rate
▪ Generally not achievable “out of the box”
▪ Several solutions need to be tested
▪ The biggest challenge is the pressure drop
DNV GL © 33 22 May 2019How DNV GL can support
COSSMOS: Optimization of complex Systems
Machinery Graphical User Interface Steady-state ,dynamic
component models & modelling platform simulations and optimization
DNV GL © 22 May 2019How DNV GL can support
DNV GL Gobal Sulphur Cap 2020 web page
https://www.dnvgl.com/maritime/global-sulphur-cap/index.html
35 DNV GL © 22 May 2019Agenda Introduction Outcome MEPC 74 Class’ perspective: Safety+reliability Project management and DNV GL project organization How DNV GL can support Future GHG reduction 36 DNV GL © 22 May 2019
Global warming (Greenhouse gases) - a global challenge
April 2018: IMO GHG Strategy with targets and policy measures
Possible measures
Short term (-2023)
▪ Review and strengthen EEDI, including new
phases
▪ Develop operational indicators
▪ Speed reduction/optimization
▪ National Action Plans
▪ Lifecycle GHG/carbon intensity guidelines for
fuels
Medium term (2023-2030)
▪ New reduction mechanism, possibly including
operational indicators
▪ Market-based measures
▪ Implementation program for low-carbon fuels
Long term (2030-)
▪ Development and provision of zero-carbon fuels
▪ Other innovative reduction mechanisms Decarbonization
37 DNV GL © 22 May 2019
Source: Maritime Forecast to 2050, DNV GL 2018MEPC 74 Result on Future GHG Reduction
▪ No change to previous strategy and goal for 2030/2050
▪ 4th GHG study to be carried out and the study result to be considered at MEPC76( Fall 2020)
▪ The MEPC aims to have the first mandatory measure(s) entering into force no later
than end-2022.
– It means the amendment resolution to be adopted in MEPC77 (2021) + 18 month period to EIF
▪ Approved Phase 3 application from 2022 for some ship types (adoption at MEPC75 (Spring 2020))
– Container ships;
– Large Gas Carriers (> 15 000 DWT);
– General Cargo Ships;
– LNG Carriers; and
– Cruise passenger ships with non-conventional propulsion.
▪ Agreed to start discussion on introducing a Phase 4 with more stringent EEDI requirements.
▪ Discussed one of the means of Speed Reduction/Limitation but no conclusion.
38 DNV GL © 22 May 2019Approved Phase 3 application from 2022 for some ship types (adoption at MEPC75 Spring 2020) 39 DNV GL © 22 May 2019
DNV GL: offering the
Broader View on
Sulphur Compliance
Dr. Fabian Kock Mr. Wei Gao
Head of Environmental Technical Support Manager
Certification
www.dnvgl.com
Fabian.kock@dnvgl.com wei.gao@dnvgl.com
+49 172 4044 585 +86 21 13817104575
The trademarks DNV GL®, the Horizon Graphic and Det Norske Veritas®
SAFER, SMARTER, GREENER are the properties of companies in the Det Norske Veritas group. All rights reserved
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