With the number of ships with scrubbers approaching 600, exhaust gas cleaning is now firmly established as the main alternative to low sulphur fuel for compliance with MARPOL Annex VI regulation 14.
While scrubbers have proved robust and reliable, what should a ship operator do in the unfortunate event of malfunction or breakdown? Through its own workshops, and regular participation in conferences and training events, EGCSA has sought advice from legal experts and marine regulators on this important question.
Open communication needed
There is recognition that, as with all properly maintained and operated equipment, there will be occasion when operation could become limited because of a system issue and that this could vary from an instrument malfunction, which does not impair SOx removal, to a more substantial problem that completely prevents system operation.
The key advice that EGCSA has received is that ship operators should be open and advise flag and coastal/port state without delay of the issue and remedial action that is being taken.
System breakdown – not immediately non-compliant
In the event of a problem preventing system operation, the ship would not be considered as being in immediate breach of the regulations because non-compliance would be unintentional and the provisions of regulation 3.1.2 of MARPOL Annex VI would apply.
If EGCS operation is not possible, the ship is advised to change over to compliant fuel. However, if there is no compliant fuel on board, the ship should be allowed to complete the current leg of its voyage without deviation and then carry out repair works or bunker compliant fuel.
Instrument malfunction – alternative demonstration of compliance
The majority of exhaust gas cleaning systems are approved according to ‘Scheme B’ – performance confirmation by continuous monitoring of exhaust emissions, with daily checks of key system operating parameters.
However, most if not all EGCS also have fully integrated pushbutton control with data logging of the key system operating parameters e.g. flow rates, temperatures & pressures, as well as the mandatory monitoring of wash water discharges, regardless of which approval Scheme is used.
Should the continuous emissions monitoring system (CEMS) malfunction for example, flag and port state should be informed and the CEMS should be fixed soonest (i.e. before or at next port). However, again the ship should not be considered as being in immediate breach of regulations.
In a similar way to Scheme A (which does not require CEMS), other system operating parameters can be used to confirm if the EGCS is continuing to operate normally and Port State Control can, if necessary, compare logged system operating parameters with reference data in the EGC System Technical Manual (ETM-B) to confirm correct scrubber operation and therefore vessel compliance during the downtime period.
What could PSC ask?
Ship operators need to be aware of national and local regulation and should recognise that the approach of different authorities may vary. The diagram at this link shows how a system issue might be managed and the interaction with port state could proceed. Typical questions that PSC could ask include:
- WHAT is the problem?
- WHEN did it happen?
- WHAT has been done to repair?
- WHAT records have been taken?
- Is emission abatement COMPROMISED?
- Is there compliant FUEL onboard?
- Are there SAFETY implications?
A visit by PSC is likely to involve checks of documentation and logs of emission monitoring and system operating data, as well as a system inspection. The ship should, therefore, ensure that EGCS operation and maintenance is as per the technical (ETM A/B) & monitoring (OMM) manuals. The EGCS record book should also be kept fully up to date with all equipment maintenance, adjustment and servicing, including details of regular verification checks of the emissions monitoring system.