Come 2015, owners operating in emissions control areas (ECAs) will have only three choices to comply with mandatory 0.1% sulphur levels; burn marine distillates, switch to liquefied natural gas; or install a scrubber system. Trouble is, 2013 is only just around the corner so decisions must be made now. And this is – understandably – heightening debate around the efficacy of available technology and emissions measurement techniques.
There are major players in the scrubber supply market such as Wartsila, Hamworthy and Aalborg. These are substantial engineering companies with excellent reputations all saying that their scrubbing technology is an effective and viable reality. Ultimately though, proving this depends upon the provision of reliable and accurate measurement.
At present, scrubber guidelines (MEPC 184(59)) allow for two methods of approval, Scheme A or Scheme B. Scheme A demands initial certification of performance followed by periodic survey with continuous operating parameters and daily emission checks to confirm performance in service. Scheme B requires performance confirmation by continuous monitoring of emissions with daily operating parameter checks.
Kittiwake Procal is firmly of the opinion that Scheme B should be the single allowable method. Firstly, despite scrubbers being used ashore and on tankers for many years, this is a relatively new technology for emissions control on ship. To mitigate any technical uncertainty that may exist, despite numerous successful trials, Scheme B gives complete and ongoing assurance of emissions at exit from ship, whereas Scheme A does not. In addition, if continuous emissions monitoring systems (CEMS) are not fitted there is a potential risk that the indirect Scheme A method of monitoring system parameters could result in non-compliant emissions being undetected between daily emission spot checks – particularly undesirable in port and ECAs. Continuous monitoring of exhaust gas emissions is the only way to provide complete reassurance, no matter the type of scrubber system installed.
Furthermore, whilst CEMS for Scheme B must be approved according to MEPC 184(59), the daily spot checks required under Scheme A risk use of unapproved portable analysers that are neither ranged appropriately for a very low level of SO2 emissions (less than 20ppm) nor meet the performance specifications appropriate for the application. Due to the manual method of obtaining an emissions reading using a portable analyser, there is risk of an inconsistent and non-representative result, not to mention the associated safety risks if an access point to a hot flowing exhaust needs to be opened and a hand held probe inserted. There are further persuasive points that can be made, but essentially the argument centres around the provision of accurate and reliable measurement that provides a simple means of determining compliance, and the adoption of the same methodology regardless of vessel location, providing reassurance and clarity.
Ultimately, the clock is ticking and whether shipowners and operators choose to switch between high and low sulphur fuel or install a scrubber, CEMS has a central role to play.
Martin Lucas, Managing Director, Kittiwake
Fairplay, December 2011


