Yves Vandenborn, Director of Loss Prevention, and Akshat Arora, Senior Surveyor, at the Standard Club on Wednesday (11 December) published an industry guidance on scrubber systems informing on the latest list of ports with discharge bans, considerations of scrubber types, and equipment breakdown; the article has been shared with Manifold Times:
In a few weeks, IMO’s ‘global sulphur cap’ will take effect. The permitted levels of SOx in ship emissions will be restricted in association with the revised MARPOL Annex VI, ie the current sulphur limit of 3.5% of any fuel oil used onboard ships will be reduced to 0.5% from 1 January 2020, except for ships using ‘equivalent’ compliance mechanisms.
It is yet to be proven how reliable the quality and supply of low sulphur compliant fuel (LSFO) is. There is a possibility that the price of high sulphur fuel oil (HSFO) could see a sharp decline in 2020.
The ‘equivalent’ compliance mechanism includes fitting ships with an Exhaust Gas Cleaning System (EGCS), or scrubber that cleans exhaust gasses from the engines. Ships with scrubber installations are allowed to run on HFSO under the new regulations. Considering fuel price differentials, it is possible for shipowners to benefit from the lower prices of HSFO by choosing this method of compliance with the regulations.
Should members elect to continue operating on HSFO with scrubbers, they will need to consider a few factors which are outlined below.
Exhaust Gas Cleaning Systems
The available SOx scrubbing technologies fall into two main categories: dry and wet scrubbing systems.
Dry scrubbers, as the name implies, do not use water or any liquid substances to carry out the scrubbing process. Instead, the system exposes hydrated lime-treated granulates to the exhaust gas to create a chemical reaction that removes the SOx emission compounds. They are more commonly used on land-based installations and not so common for marine use.
Wet scrubbers are more common in the marine industry. These fall into three design variations:
Overview of scrubber discharge bans
Some port states have concerns regarding water borne sulphates resulting from the neutralizing process being discharged into the sea, as they have been known to significantly change the pH of sea water. The changes may have an impact on marine biodiversity, especially among fish species. Therefore, discharge limitations set by the IMO and various region regulations stipulate that the pH of the wash water discharge must be measured prior to overboard discharge.
Wash water from open loop scrubbers must be treated and monitored at the inlet and outlet to ensure that it conforms with the MEPC 259(68) discharge criteria, with no risk of harm to the environment. However, some coastal states and ports have implemented local regulations with more stringent requirements for the quality of wash water being discharged overboard. Details of these ports are given below:
|China||Discharge prohibited in inland & coastal ECAs and Bohai Bay waters.
**Ban in the entire coastal domestic ECA may be announced soon.
|Hong Kong||Discharge may be allowed but vessels are to request permission to use non-compliant fuel 14 days before arrival.|
|Singapore||Use of open loop scrubbers prohibited within Singapore port limit.|
|Malaysia||Use of open loop scrubbers prohibited throughout Malaysian territorial waters & ports.|
|India||Generally permitted but some ports may have more stringent requirements in place.|
|UAE||Abu Dhabi may allow discharge overboard if free from pollutants, whilst scrubber sludge should be discharged to a licensed waste disposal contractor.
Fujairah has banned the use of open loop scrubbers in territorial waters.
|Belgium||Discharge prohibited in ports and inland waterways.|
|Germany||Discharge prohibited in inland waterways and on the Rhine.|
|Lithuania||Discharge prohibited when in port.|
|Latvia||Discharge prohibited in territorial and port waters.|
|Ireland||Discharge prohibited in ports of Dublin, Waterford and Cork.|
|Norway||Discharge prohibited in Norwegian fjords (visible emissions reduction also required).|
|Panama||Use of open loop scrubbers prohibited in Panama Canal waters.|
|Hawaii||Currently permitted subject to special conditions.|
|California||Use of scrubbers is banned.|
Members with an open-loop (or hybrid) EGCS system installed on their ships would need to be mindful when their ships operate in regions where scrubber discharge is banned. The ships will need to switch to either closed-loop mode or to compliant fuel well in advance of the ship’s arrival at such ports.
Scrubber type considerations
Vessels' operational profiles will differ vastly, and each ship will have its own unique solution. Some of the factors for deciding which type of scrubber to install, include:
Scrubbers, like any other piece of mechanical equipment, can break down from time to time. In the case of an exhaust gas scrubber installation, it is likely this will involve the external support equipment, pumps, pipes, valves, etc. Apart from the nozzles, there is very little that is likely to fail within the scrubber itself.
The wash water from scrubbers is acidic and highly corrosive. The effects are aggravated by high temperatures of exhaust gases. Therefore, the structural integrity of the scrubber and associated pipework will need to be regularly checked for signs of leakage or corrosion.
There are recent reports of scrubber pipework failing very early in the life of the installation, sometimes within six months of commissioning. These failures could be traced back to quality issues during its installation. Corrosion has been discovered in pipes leading from the scrubber and in way of the residue treatment systems which handle acidic substances.
Pipes in these systems should ideally be manufactured from a corrosion resistant material, but as the demand to install scrubbers moves at an increasing pace, these materials are short in supply.
As an alternative, steel pipes are applied with a corrosive resistant protective coating and, like any other protective coating, for example ship shell coatings, the preparation of the substrate is very important. If the preparations are not carried out correctly, for example correct cleaning procedures with etching or pickling to remove grease and acid deposits from the internal surfaces of the pipe and for all corrosion products (for example surface rusting) to have been removed, the coating will not bond with the substrate correctly leading to an early failure of the coating. Similarly, it is essential the complete recommended coating system is correctly applied to the required dry film thickness (DFT) as set out by the coating manufacturer.
When overseeing a scrubber installation, members need to pay extra attention to the installation and coating of the system pipework, remembering that welding onto the surface of a pipe may well destroy any internal coating and could lead to an unexpected early failure of the pipe.
Failure of the above equipment will render the scrubber non-operational, making it mandatory for the ship to report it to the flag and relevant port state authority immediately.
It is recommended that the Ship’s Implementation Plan (SIP) include a section on ‘contingency planning’ as there could be a potential non-compliance and off-hires in circumstances where the scrubber system breaks down or is defective.
In case of a breakdown or reduced performance, members would need to notify both the flag and port states immediately. This should be viewed as a temporary non-compliance, but the vessel would not be in breach of the regulations if the vessel immediately took steps to change over to a compliant fuel. If a compliant fuel is not available, it must be bunkered at the next port alongside the necessary repairs.
Difficulty in repairing scrubber units while the vessel is in remote regions should be anticipated. Due diligence and preparation would require members to revisit their critical spares list, and in consultation with the manufacturer, add items which are most likely to break down, including the continuous emissions monitoring system.
The Exhaust Gas Cleaning Systems Association (EGCSA) has produced a logic flow diagram which examines this scenario and provides guidance on appropriate steps to rectify the problem and remain compliant with MARPOL Annex VI, this is shown here. The Association also published a guide which can be found here.
The case for scrubbers largely depends on the ship’s trading pattern, fuel availability and price differential between the high and low sulphur (compliant) fuel oil.
While this compliance option may be lucrative for large vessels with high fuel consumption, in order to gain the competitive edge, the shipowner/operator would also need to consider the right technology and utilize reliable suppliers as any breakdown or malfunction of the scrubber could lead to significant fines.
The contractual agreements would also need to consider the down time for scrubber installation and other aspects which are covered in the club's article discussing charterparty FAQs.
With thanks to Charles Taylor Adjusting / Marine for their contribution to the technical aspects of this article
Source: The Standard Club
Photo credit: Manifold Times
Published: 12 December, 2019
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