Emissions monitoring: the continuous approach
As ship operators and regulators struggle with compliance and enforcement of emissions regulations, technology enabling continuous monitoring may be the answer, writes Chris Daw, managing director, Parker Kittiwake Procal.
As increasingly stringent global emissions regulations continue to evolve, the reduction of SO2, CO2 and NOx emissions will challenge growing numbers of stakeholders across the global shipping industry. Whichever compliance solution is employed in order to reduce emissions, the importance of monitoring emissions gasses continually is paramount in order to avoid costly penalties for non-compliance. Proven, efficient and accurate analysers are readily available which enable continuous monitoring, on-board and in real time, to ensure that the compliance solution employed is operational and effective. Continuous emissions monitoring technology has the ability simplify reporting while at the same time enabling a level playing field when it comes to compliance.
Universal contention remains around monitoring and recording of compliance; an efficient enforcement strategy on an international level is still to be defined. Currently bunker delivery notes (BDN) showing the sulphur levels in fuel taken onboard are used to evaluate SO2 levels. These could also be used to monitor CO2, NOx and particulate matter. However, this approach is far from fit for purpose, especially when many relatively inexpensive technologies are readily available on the marketplace to provide a monitoring solution.
A recent consultation by the UK's Maritime and Coastguard Agency suggested that it could prove hard for port state control (PSC) authorities to check if a vessel with a scrubber onboard was actually using it. This prompted Meindert Vink, senior policy advisor, Netherlands Shipping Inspectorate to state that he had faith in scrubber technology, especially if combined with tamper-proof continuous monitoring technology. He noted that this would make it straightforward for PSC to simply check the record on paper. Continuous monitoring of sulphur emissions is one of two methods that can be used to certify scrubbers, according to IMO guidelines.
The Clean Shipping Coalition (CSC) has suggested to the International Maritime Organisation (IMO) that continuous monitoring technologies that monitor emissions directly during the entire journey should be installed on all ships. In its submission to the IMO last year, the CSC said BDNs leave too much room for uncertainty.
The pitfalls of the BDN approach are echoed by members of the recently established Trident Alliance, which is working hard with national and European authorities and NGOs to define how effective enforcement of sulphur regulations can be achieved on the high seas.
The marine industry is already familiar with continuous emissions monitoring systems (CEMS). It is the most popular method of verifying the performance of scrubbers according to IMO guidelines.
CEMS has the ability to monitor gases from the combustion of residual and distillate fuels such as SO2, CO2 and NOx. By transmitting this information ashore combined with identity, position and port calls obtained from the AIS (Automatic Identification System), PSC can easily confirm compliance in port, in ECAs and in international waters.
As those involved in this debate increase their knowledge of the capability of CEMS, growing numbers are voicing their support of this technology as a viable solution. CEMS that continuously monitor emissions in the stack – ‘in-situ’ – are most effective and do not require, often expensive and difficult to maintain extractive sampling. In-situ monitoring provides a continuous, real time monitoring of the content of exhaust gases, with data provided instantaneously on a screen that can be installed in the engine room and on the bridge.
An instrument such as Parker Kittiwake’s Procal 2000 can monitor up to six exhaust gases and a typical system could monitor up to six emission points to monitor gases such as SO2, CO2 and NOx. The analysers are connected to a data acquisition system, which displays data logs and retransmits the monitored concentrations and SO2 and CO2 ratio – in accordance with IMO regulations – without any manual intervention. This, linked with the low maintenance requirements, makes it an ideal marine monitoring system. Moreover, by adding a flow device to the exhaust and sending the signal to the CEMS, the emissions in mass units - for example kg/h - can be displayed and logged, enabling fuel burn to be monitored as required by the planned MRV regulations.
When it comes to environmental compliance – no matter how efficient and effective – the cost is understandably the first question asked. However this should not present a stumbling block for CEMS. The Procal analyser system, for example, costs approximately £25,000. The United States has stated that it will enforce strict ECA compliance and could enforce penalties of $25,000 a day. Although there may be significant variances in Europe (the Netherlands is considering a six-figure sum or detentions), this still makes any investment in CEMS equipment relatively inexpensive. Widespread uptake would also reduce overall costs.
As environmental regulation continues to increase in scope and reach, ensuring a robust solution is in place to not only comply, but also to be able to prove compliance with sound evidence, is key. A simple, inexpensive solution that is proven, reliable and leaves no room for ambiguity can reassure shipowners that they are not leaving themselves open to the risk of hefty fines they can ill-afford.
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