A notice dealing with instances of alarms triggering on SOx scrubbers has been issued by the USCG to cover vessels operating in the U.S. portion of the North American Emission Control Area (ECA) and the U.S. Caribbean Sea ECA.
The USCG says that while the IMO is considering recommendations for amendments to the MEPC.259(68) 2015 Guidelines for Exhaust Gas Clean Systems, owners and operators of vessels with continuous emissions monitoring systems can take actions of their own to satisfy USCG expectation
USCG advice is to address raised by the triggering of alarms caused by short-term temporary emission exceedances due to predictable operations of vessels, such as engine load changes by having the scrubber manufacturer identify, in the scrubber manual, the manufacturer’s solutions to these issues. Owners and operators can also address the issues in the ship’s Safety Management System (SMS).
The manual or SMS system should identify the temporary exceedance that may be expected to occur under specific operating conditions and the length of time each exceedance would be expected to continue. The manual or SMS system should also clarify the maximum amount of time that would be considered to be a short-term temporary exceedance before the vessel would need to switch over to compliant fuel.
Vessel representatives for vessels fitted with EGCSs should clarify the procedures to be taken in response to these conditions through their SMS. Specifically, the SMS should reference the manufacturer’s guide, address approved short-term instances when the EGCS alarms may sound, and how, when, and where to document these short term instances.
The SMS should also have instructions regarding notification when the emissions exceed the allowable SOx limit for a period that is longer than a short-term instance. Specific examples with time ranges should be addressed in the SMS, along with procedures to commence corrective action. Port State Control Examiners may review these procedures during the course of a normal exam and verify that these instances were documented and that appropriate actions were taken.
Although MEPC.259(68) does not contain requirements to report a temporary, short term SOx exceedance, in US waters an EGCS failure which meets the criteria for a marine casualty, as clarified in Navigation and Vessel Inspection Circular (NVIC) 01-15, should be reported as required.
Image: Alfa Laval.