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Is Your CEMS Compliant?

 
September 4th 2014
January 1st 2015 is a very important date for shipping companies that enter US and Northern European waters.  The New Year heralds the need to comply with the IMO Sulphur Oxides (SOx) Regulation 14.  Namely, within Emissions Control Areas (ECA) a limit to SOx emissions of 0.10% m/m comes into force. This limit may be achieved through the use of low sulphur fuels, or by emissions mitigation systems such as exhaust scrubbers.

The measurement of SOx emissions from exhaust scrubbers is defined in MEPC 184(59), and the NOx Technical Code.  In this article we aim to describe the requirements for the measurement of SOx emissions within a scrubber application.

Measurements of CO2 and SO2 are required on a daily basis or through continuous emissions monitoring of the scrubber while inside an ECA.  These measurements are taken from the exhaust stream and the ratio of their concentrations determines if the scrubber emissions are compliant with Regulation 14.

However, the continuous emissions monitoring system (CEMS) must be built to regulation specifications or the data it produces will not be accepted by regulating agencies! Harsh Marine Conditions Type Approval from any of the Class Societies is not a measure of Regulation 14 compliance and cannot be used as such.  Compliance is only achieved by adhering to the following basic requirements found in MEPC 184(59) and the NOx Technical Code, Appendix 3:

· Extractive sampling of the exhaust stream

· Heated filter to prevent solid particles from entering the sample stream

· Heated sample lines to maintain high exhaust gas temperature during transport, preventing the formation of    deposits and plugging

· Sample conditioning which cools and removes moisture content from the sample, preventing sulphuric acid   damage to the analyser

· Non-dispersive infrared (NDIR) analyser to measure CO2 and SO2

· Calculation of the CO2 / SO2 ratio per MEPC 184(59) at a frequency of at least 0.0035 Hz

· Regular analyser calibration via span gas to ensure accuracy of results

In some cases regulating agencies make allowance for the use of alternative continuous emissions monitoring methods. However, such methods are only compliant if accompanied by express written approval.

It is extremely important to ensure the scrubber CEMS used to prove compliance with Regulation 14 is built to regulation specifications, or else the data it produces will not be accepted and compliance will not be recognized.


The content for this article was provided by Charles Hansard – Director of Sales (Europe) for GreenLink Systems - www.greenlinksystem.com - +44 20 3393 9180 – chansard@greenlinksystem.com