8/9/2017: Cruise Ship National Center of Expertise Field Notice 01-17: Exhaust Gas Cleaning System Short-term Temporary SOx Exceedances

The Cruise Ship National Center of Expertise released Field Notice 01-17 Exhaust Gas Cleaning System (EGCS) Short-term Temporary SOx Exceedances to provide Coast Guard expectations for dealing with alarms from EGCSs, where such alarms are triggered by short-term temporary emission exceedances due to predictable operations of vessels, such as engine load changes. This notice is intended for vessels operating in the U.S. portion of the North American Emission Control Area (ECA) and the U.S. Caribbean Sea ECA.

While the International Maritime Organization considers recommendations for amendments to the MEPC.259(68) 2015 Guidelines for Exhaust Gas Clean Systems, owners and operators of vessels with continuous emissions monitoring systems can address issues raised by these occurrences by having the scrubber manufacturer identify, in the scrubber manual, the manufacturer’s solutions to these issues. Owners and operators of such vessels can also address the issues in the ship’s Safety Management System (SMS).

The manual or SMS system should identify the temporary exceedance that may be expected to occur under specific operating conditions and the length of time each exceedance would be expected to continue. The manual or SMS system should also clarify the maximum amount of time that would be considered to be a short-term temporary exceedance before the vessel would need to switch over to compliant fuel.

Vessel representatives for vessels fitted with EGCSs should clarify the procedures to be taken in response to these conditions through their SMS. Specifically, the SMS should reference the manufacturer’s guide, address approved short term instances when the EGCS alarms may sound, and how, when, and where to document these short term instances. The SMS should also have instructions regarding notification when the emissions exceed the allowable SOx limit for a period that is longer than a short term instance. Specific examples with time ranges should be addressed in the SMS, along with procedures to commence corrective action. Port State Control Examiners may review these procedures during the course of a normal exam and verify that these instances were documented and that appropriate actions were taken.

Although MEPC.259(68) does not contain requirements to report a temporary, short term SOx exceedance, an EGCS failure which meets the criteria for a marine casualty, as clarified in Navigation and Vessel Inspection Circular (NVIC) 01-15, should be reported as required.

If you have any questions regarding this notice, please contact the National Technical Advisor at 954-767-8021, or via e-mail at CSNCOE@uscg.mil, or the Office of Commercial Vessel Compliance, Foreign and Offshore Compliance Division at portstatecontrol@uscg.mil.

For more information, view Field Notice 01-17 .

This blog is not a replacement or substitute for the formal posting of regulations and updates or existing processes for receiving formal feedback of the same. Links provided on this blog will direct the reader to official source documents, such as the Federal Register, Homeport and the Code of Federal Regulations. These documents remain the official source for regulatory information published by the Coast Guard.

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