MARITIME

SOx Compliance
Operational Experience 2020

Fabian Kock

1 DNV GL © 21 August 2020 SAFER, SMARTER, GREENER

Agenda

 Bunker price development

 Scrubber retrofits: Current situation
 Remote survey options for Scrubbers
 Challenges with HSFO stored on board
 Challenges with Scrubbers in operation
 Options in case of sensor failures
 Fuels update

DNV GL © 21 August 2020

Bunker price development

Bunker prices VLSFO vs. HSFO

800.00 400.00

700.00 350.00
VLSFO Bunker Prices (0.5% Sulphur), Singapore

HSFO 380cst Bunker Prices (3.5% Sulphur), Singapore

600.00 300.00
Price Difference

Price difference USD/tonne

350 USD/t
Bunker price USD/tonne

500.00 250.00

200 USD/t difference -> reasonable payback

400.00 200
200.00
The future?
300.00
60 USD/t 150.00

200.00 100.00

100.00 50.00

0.00 0.00
03-Jan-2020 02-Feb-2020 03-Mar-2020 02-Apr-2020 02-May-2020 01-Jun-2020 01-Jul-2020 31-Jul-2020

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Scrubber retrofits: Current situation

World Fleet Under SOx Scrubber Retrofit

World Fleet, Total SOx Scrubber Fitted

3500 World Fleet Under SOx Scrubber Retrofit 350

3000 300

2500 250
2459
Total number installed

Registered in GISIS (2020-08-12)

in repair yard
2000 200

1500 150

1000 100

69
500 50

0 0

Source: Clarksons

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Remote survey options for Scrubbers

Commissioning at quay side and/ or sea trial

Is remote verification/ Survey of commissioning scope

possible?
Some default pre-conditions:

 Only applicable for “Scheme B” certification according to

MEPC.259(68) (continuous emission monitoring with
parameter checks)

 Only for sister vessel with same scrubber maker

 Sea trial attendance by class for the commissioning test on the first vessel of a series of an alteration project with satisfactory
result. Sea trial attendance for same serial in different yards will be evaluated on case by case base.
 The commission test items at quay side is preferably carried out in the same retrofit yard and by the same surveyor in charge of
retrofit
 Due to validity of calibration of essential sensors (PAH, turbidity or SO2/CO2) the commissioning at sea should be performed
shortly after the successfully completed quay test (validity of calibration is normally 90 days)
 Quay test completion in yard may be a trigger for a remote survey.
 Kick off meeting will be arranged before quay test start or even earlier for each serial in different yards.

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Remote survey options for Scrubbers

MARPOL related: Which items have to be finalised in the yard?

Following items have to be witnessed by surveyor:

 Verification of EGC Installation:

– The physical installation of the EGCS to be inspected
 Continuous exhaust gas monitoring system (CEMS) – Emissions to Air:
– Verifications of system layout
 Analyser Verification Test (SO2 and CO2):
– Verification of gas analyser calibration (calibration gases to be provided by
the applicant!)
 Continuous washwater monitoring system:
– calibration (calibration kids to be provided by applicant!)
 Data recording and compliance report:
– Verification of recorded Emission Data and Compliance Report

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Challenges with HSFO stored on board

HSFO on board after March 1st 2020?

Did you get stuck in yard with HSFO in your fuel tanks before March 1st
2020?

 IMO does not consider COVID-19 to fall under force majeure (the fact that DNV GL might
consider Covid-19 as force majeure is irrelevant in this context).
 In Circular letter No.4204/Add.1 IMO is asking “close cooperation among all Member States to overcome
challenges related to the implementation and enforcement of the relevant IMO instruments.”
 There is no general procedure in place how to deal with ships, which are currently ion dry dock for
installation of EGCS, having non-compliant fuel oil on board.
 (As a side note: The “unforeseen delay” clause in MARPOL only applies to new buildings and not
alterations/conversions).
 This being said, DNV GL acting as recognised organisations on behalf of Administrations is not in the
position to make decision, which deviate from an Annex of MARPOL and it is up to the flag state to
define actions.
 A ship in dry dock and not provided with Flag authorization MEPC.1/Circ.881 will apply, implying that the
PSC, flag and ship needs to agree on contingency measures, possibly resulting in debunkering.

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Challenges with HSFO stored on board

Proposed actions to be agreed with flag state

Did you get stuck in yard with HSFO in your fuel tanks before
March 1st 2020?

The following proposal is feasible option, which can be proposed to the flag state, and already
has been approved by some flag states:

1. Bunker survey carried out by DNV GL surveyor reporting remaining Volume of non-compliant
fuel, involved tanks, valves and seals.
2. Photographs of sealing arrangement to be provided including copy of tank arrangement
drawing.
3. Extract of ORB stating tanks involved, sealing arrangement and remaining ROB of HSFO by
CE.
4. Item 1 could be exchanged with a bunker survey report carried out by an independent
recognized bunker survey organization.
5. Issuance of Survey statement or Statement of fact covering items 1. to 4.
6. DNV GL or owner approaching flag state asking for “close cooperation among all Member
States to overcome challenges related to the implementation and enforcement of the
relevant IMO instruments.”

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Operational experience

Operational experience: DNV GL Scrubber experience questionnaire

 Questions were send out to 61 owners/operators, having in total

802 “Scrubber years” of experience
 Response rate was 26%
 Questionnaire consisted of 23 questions
 Planning
 Installation
 Operation
 General comments
 All answers here:
https://forms.office.com/Pages/AnalysisPage.aspx?id=Kw7
xrem21kG-L8ErtWYBnDHg2OjRl51NvnmLU-
FvM95UNFU1NEhHVEpQNDk3S0RRSUFDMEVHOEE0TS4u&
AnalyzerToken=pUy8jUfkJzzhwgMRHLVfympdNf53KMZM

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Operational experience – frequent failures

Operational challenges – what fails most often?

Overboard discharge pipe after 3 month of operation

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 Operational experience – frequent failures

Components most prone to failure – corrosion

Overboard discharge pipe after 3 Leakage

Damaged epoxy coating and subsequent hole
month of operation (pipe design:
carbon steel pipe + special coating)

Based on experiences, DNV GL updated in 2017 its rule requirements for SOx scrubber overboard
piping, requiring annual thickness measurements of the scrubber overboard valve distance piece.
For more info see DNV GL class rules, Part 7, Chapter 1, Section 2 3.1.9

11 DNV GL © 21 August 2020

Operational experience – frequent failures

Components most prone to failure - sensors

 Having reliable monitoring equipment is of utmost

importance since they are the basis to show compliance of
the system
 Sensor failure due to e.g. fouling
– Understanding why the sensors fail
– Calibration of sensors and missing calibration certificate
– “Faulty alarms”
– Sensor maintenance is important, variations form ship to
ship should be observed
 MEPC.1/Circ.883 “GUIDANCE ON INDICATION OF
ONGOING COMPLIANCE IN THE CASE OF THE FAILURE OF
A SINGLE MONITORING INSTRUMENT”

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 Sensor failures

Actions in case of MARPOL related failure: MECP.1/circ883

ALARM – EMISSION
EXCEEDANCE

SHORT-TERM TEMPORARY SENSOR FAILURE

MALFUNCTION
EMMISSION EXCEEDANCE
Depending on flag
requirement
INTERIM INDICATION
RECTIFIED WITHIN
yes CONTINUED EGCS OPERATION CA yes OF ONGOING
ONE HOUR
COMPLIANCE

NOTIFICATION TO
no yes CA
AUTHORITIES

NOTIFCATION TO
SUFFICIENT AUTHORITIES
ACCIDENTAL
COMPLIANT FUEL ON no CA
BREAKDOWN PROPOSED COURSE
BOARD no
OF ACTION

13 DNV GL © 21 August 2020

Sensor failures

Models used in other sectors: Torque display in cars

• Torque measurement shafts

installed in cars?
• No! Torque is only measured on
the test bed during design and a
model is generated based on the
input of other sensors

BMW: Sport display

DNV GL © 21 August 2020

Sensor failures

1. Generate “Certified” Model (neural network) of EGCS parameters (offline)

Get (offline) data “Certified” Neural network

of EGCS under Neural network coefficients stored on board
“normal”
operation:
• Engine load(s)
• Flow rates
• Temperatures
• SO2
• CO2
e.g. rbfcreate()
• pH
• …

15 DNV GL © 21 August 2020

Sensor failures

2. Actions in case of sensor failure (onboard): “Virtual sensor”

“Certified” Neural network

coefficients stored on board:
“Virtual sensor”
Onboard data of
EGCS in case of
sensor failure
• Engine load(s)
• Flow rates SO2
• Temperatures
• SO2
• CO2 CO2
• pH
Input n-2
• …

e.g. rbfinterp()
excel sheet with NN coeffs.
….

16 DNV GL © 21 August 2020

Update on fuels

ISO PAS 23263

 Fuels should still be purchased according to ISO 8217:2017
 Kinematic viscosity is expected to range widely. Particular
attention should be given to the correct temperature and viscosity
settings in the fuel system.
 Temperature control will be important for maintaining cold flow
properties and avoid wax formation.
 Fuel blend formulations are expected to vary widely, and suppliers
cannot guarantee the compatibility between different fuels of
which one or both contain a residual component. Managing such fuels
on board relies on the competence of the fuel purchaser and the
ship’s crew. Ship operators should aim to minimize commingling
of fuel to prevent incompatibility issues.

17 DNV GL © 21 August 2020

Fuels update

DNV GL Rules: “ER” notation and qualifier “Enhanced”

DNV GL class notation ER with additional voluntary qualifier “Enhanced”

for installations with enhanced availability additionally requires:

 Approval of failure mode report for the EGCS control and safety system
 Manufacturer and Product Certificate (MC and PC) for EGC Unit
 Redundant pumps
 Sea-water supply system shall be connected to at least two sea-water
inlets, preferably on opposite sides of the ship
 Sea-water supply suction lines for systems with EGCS pen, EGCS hybrid
and EGCS closed qualifiers shall be provided with strainers which can be
cleaned without interrupting the water supply
 EGCS units (any type) shall be provided with works (W) certificate for the
scrubber unit material and the welding of joints shall be carried out by
qualified welders using approved welding procedure specifications and type
approved welding consumables

18 DNV GL © 21 August 2020

You need more information?

DNV GL Global Sulphur Cap 2020 webpage and DATE

https://www.dnvgl.com/gsc

19 DNV GL © 21 August 2020

 Thank you

Dr. Fabian Kock

Head of Environmental Certification

www.dnvgl.com
Fabian.kock@dnvgl.com
+49 172 4044 585
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20 DNV GL © 21 August 2020