IBIA participates as scrubber association examines issues ahead of 2020
Scrubber manufacturers are delighted about the 2020 global 0.50% sulphur cap for marine fuels, but there are still some issues to overcome before owners rush to install abatement technology. These include uncertainties caused by the regulatory framework and elements of perhaps unfairly rigid environmental performance demands, a recent industry workshop heard.
The Exhaust Gas Cleaning Systems Association (EGCSA) held a meeting in London from 30 November to 1 December 2016, of which the first day was open to its members, associate members and a handful of guest speakers, including IBIA.
In a very enlightening presentation, Per A. Brinchmann, VP Technical, Wilh. Wilhelmsen ASA (WWL), explained current challenges for owners. The company has installed, and are operating globally, with hybrid scrubbers on five vessels so far, having undertaken its first retrofit in 2013.
Owners are facing financial, technical and political risks if they install a scrubber, he said. One problem is that there is no ‘grandfathering’ of environmental performance technology, which combined with uncertainty about future regulatory requirements – for example with regards to washwater standards or tightening emission parameters – means early owners may find their systems obsolete if technical performance falls short of requirements. He also said continuous monitoring of emissions, which is one of two possible options for approval of an exhaust gas cleaning system (EGCS), is an as yet unproven requirement in ship emissions.
Brinchmann highlighted that continuous monitoring can even have some unfortunate side effects that actually discriminates against EGCS as well as technology used to control nitrogen oxide (NOx) emissions, because they record short term, but unavoidable emission standard failures caused by specific operational conditions that impact on the engine load.
He shared an example from WWL, showing that one of its vessels achieved an average sulphur emission reduction equivalent to using fuel with just 0.04% sulphur, which makes it outperform ships using fuels with maximum 0.10% sulphur. However, during the journey, the measured emission equivalents peaked above 0.10% sulphur in short bursts.
Regulators in Europe have told WWL that they have just 15 minutes to fix such emission peaks before the vessel is considered non-compliant with a 0.10% sulphur limit. Unless the peak is just a short burst caused by a sudden shift in the engine load that self-adjusts, this is an impossibly short time for the ship’s engineers to investigate and rectify the problem. Considering the vessel’s average sulphur emissions is equivalent to just 0.04%, this seems an unfairly rigorous requirement and puts an otherwise over-performing ship at risk of penalties.
As a potential customer, Brinchmann said what WWL wants from the scrubber manufactures is improved technology, better and more reliable sensors, less piping, valves and pumps, better particle removal, better wash-water treatment systems both in open and closed loop, and less energy consumption to run the systems.
The EGCSA workshop also discussed how the industry comes up against politically motivated problems. There seems to be an undercurrent of scepticism driven in part by those with a political agenda to prevent all use of heavy fuel oil (HFO) by ships. Brinchmann also warned that the shipping industry had done some harm when resisting the introduction of the 0.10% sulphur limit in emission control areas in 2015, having gone looking for evidence that the technology was not ready to assist with compliance.
One of the most vexed issues that keep coming up is the impact of scrubber washwater on the marine environment. Several European countries have banned vessels from using open loop systems within their coastal waters and on inland waterways, and some are discussing it. The EGCSA workshop heard two presentations on the subject.
Dorte Kubel, Ministry of Food and Environment of Denmark, Environmental Protection Agency, spoke about research into the impact on marine plankton undertaken by the Technical University of Denmark, which has conducted both laboratory and field testing. The laboratory tests suggested some negative impacts when the plankton was exposed to individual components, such as specific metals, but the full ‘cocktail’ seemed to have had a much smaller impact than exposure to single contaminant exposure. The field testing found that vanadium, nickel, chromium and lead are elevated in scrubber water but it wasn’t clear what the impact on plankton might be.
Mark West, a consultant who has been involved in washwater sampling programmes, later explained that the lead may come from construction materials as opposed to the washwater itself. Vanadium and nickel seemed to be the most prevalent metals that may be attributable to washwater. As for PAHs, he said there had been no single recorded instance of the levels exceeding the limits set by the International Maritime Organization (IMO).
The EGCSA workshop also heard from Eddy van Bouwel, IPIECA, about the impact on the refining industry from the IMO’s 2020 sulphur cap decision. He reminded everyone that there is no button to push for refineries to stop producing high sulphur fuel oil (HSFO), and that there is no global forum where refineries will come together and make a decision on how to respond. Competition laws would make this illegal. This means each refiner will make their own decisions based on their own analysis of the regulation’s impact on the markets they operate in, so it will be up to individual refiners – not the sector – whether they chose to make efforts to provide the marine fuels sector with suitable products.
IBIA’s presentation provided an overview of IBIA’s input to the debate on implementing the 0.50% sulphur cap at the IMO, stressing that going from the global 3.50% sulphur limit to a 0.50% sulphur limit is not as easy as flicking a switch, neither for global refining, the bunker supply industry, or even for ships – unless they have scrubbers installed ahead of time. However, assuming full compliance with the 0.50% sulphur limit in 2020, demand for HSFO would drop sharply and it would become a niche market, catering only to vessels with scrubbers. The question then becomes whether all suppliers would continue to market HSFO if most global demand is for low sulphur fuels. IBIA’s representative at the EGCSA workshop suggested that major bunker ports with plenty of storage/delivery options will continue to have HSFO, but ongoing supply may not be viable in smaller ports unless they have regular calls from vessels with scrubbers. Moreover, ports with low HSFO turnover will not be able to sustain a spot market for this type of fuel.
The EGCSA workshop also heard a presentation of a new study highlighting the increase in CO2 emissions associated with refineries producing more low sulphur fuels for shipping, suggesting scrubbers could mitigate this. The CO2 increase argument has been heard several times before, but has to date not gained much traction with governments and their representatives at the IMO.
The mood among abatement technology providers has undoubtedly had a huge boost from the IMO’s decision in late October. Several of EGCSA’s members would probably not have survived if the 0.50% sulphur cap had been delayed until 2025. Now, as one of the providers IBIA spoke to observed, they had received more enquiries in the space of a month than they had for the preceding several years. It remains to be seen how many enquiries translate into orders, especially at a time when money is tight for many shipping companies.
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