Costs of Emission Reduction Technologies
   for Category 3 Marine Engines


   Final Report
United States
Environmental Protection
Agency

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Costs of Emission Reduction Technologies
         for Category 3 Marine Engines

                       Final Report
                   Assessment and Standards Division
                  Office of Transportation and Air Quality
                  U.S. Environmental Protection Agency
                         Prepared for EPA by
                          ICF International
                     EPA Contract No. EP-C06094
                     Work Assignment No. WA1 -8
  NOTICE

  This technical report does not necessarily represent final EPA decisions or
  positions.  It is intended to present technical analysis of issues using data
  that are currently available. The purpose in the release of such reports is to
  facilitate the exchange of technical information and to inform the public of
  technical developments.
        Protection
EPA-420-R-09-008
May 2009

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Table of Contents

1.   Introduction	1-1

2.   Technology Description	2-3
    2.1.   Baseline Technologies	2-3
          2.11  Low-Speed Engines	2-4
          2.1.2.  Medium-Speed Engines	2-4
          2.1.3.  Typical Ship Characteristics	2-4
    2.2.   Advanced Technologies	2-5
          2.2.1.  Tier I Retrofit Technologies	2-5
          2.2.2.  Tier II Technologies	2-6
          2.2.3.  Tier III Technologies	2-11
    2.3.   Fuel Switching	2-23
          2.3.1.  Vessel fuel systems	2-23
          2.3.2.  Potential vessel modifications associated with fuel switching	2-25
          2.3.3.  Modifications for fuel switching	2-28
          2.3.4.  Scenarios analyzed and cost methodology	2-29

3.   Economic Impact	3-1
    3.1.   Cost Estimation Methodology	3-1
          3.1.1.  Hardware Cost to Manufacturer	3-1
          3.1.2.  Fixed Cost to Manufacturer	3-1
          3.1.3.  Fuel Economy	3-2
    3.2.   Retrofit Tier I Technology Costs	3-3
    3.3.   Tier II Technology Costs	3-4
    3.4.   Tier III Technology Costs	3-6
          3.4.1.  Engine Modifications	3-6
          3.4.2.  Fumigation	3-7
          3.4.3.  Fuel Emulsification	3-9
          3.4.4.  Direct Water Injection	3-11
          3.4.5.  Exhaust Gas Recirculation	3-73
          3.4.6.  Selective Catalytic Reduction	3-75
          3.4.7.  Sea Water Scrubbers	3-77
    3.5.   Fuel Switching Hardware Costs	3-19
    3.6.   Differential Fuel Consumption	3-22
    3.7.   I MO Testing Costs	3-23
ICF International
EPA Contract EP-C-06-094, WA 2-08
U.S. Environmental Protection Agency
                   April 20099

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            Costs of Emission Reduction Technologies for Category 3 Marine Engines
                                         Table of Contents
List of Figures
Figure 1-1. Proposed IMO Standards	1-2
Figure 2-1. Cross-Sectional diagrams of Different Nozzle Sac Designs	2-8
Figure 2-2. Wartsila Common Rail Fuel Injection System	2-10
Figure 2-3. Comparison between SCR and HAM	2-12
Figure 2-3. HAM System	2-13
Figure 2-4. SAM System	2-14
Figure 2-5. Wetpac H System	2-15
Figure 2-6. Pressurized Fuel Emulsification System	2-16
Figure 2-7. DWI Unit for Pressurizing Water and injectors	2-17
Figure 2-8. MAN Diesel EGR Scrubber	2-19
Figure 2-9. Example of Urea SCR System for a 4-stroke engine with the reactor placed downstream of turbocharger
	2-20
Figure 2-10. Urea SCR system with Reactor Installation before Turbocharger	2-21
Figure 2-11. Seawater Scrubbing System with EcoSilencer® for a "Super Yacht" design for engines up to 3.5MW2-22
Figure 2-12. Typical Shipboard Unifuel Delivery System	2-24
Figure 2-13. Typical Fuel Tank and Delivery Systems	2-25
Figure 2-14. MAN B&W's Fuel Oil System No. 1	2-30

List of Tables

Table 2-1. Engine Modifications Currently In-Use to Meet MARPOL Emission Levels	2-3
Table 2-2. Average Engine Characteristics Used in this Study	2-4
Table 2-3. Average Ship Characteristics by Ship Type	2-5
Table 2-4. Average Auxiliary Engine Load Factors and Hotelling Times by Ship Type	2-5
Table 2-5. Key Attributes and Benefits to the Sulzer RT-flex Common Rail System	2-10
Table 2-6. Benefits and Limitations of Wartsila's DWI  Technology	2-18
Table 2-7. Typical on-board storage for heavy fuel oil  and distillate fuels by vessel type	2-27
Table 2-8. Fuel Use per Call forVarious EGA Distances (Metric Tonnes)	2-27
Table 3-1. Labor Rates	3-1
Table 3-2. Annual Research and Development Costs	3-2
Table 3-3. Average Load Factors	3-2
Table 3-4. Cost of Retrofit Kits	3-3
Table 3-5. Differential Costs for Engine Modifications  to Meet Tier II Emission Levels	3-4
Table 3-6. Common Rail Fuel Injection Costs for Mechanically Injected Engines	3-5
Table 3-7. Common Rail Fuel Injection Costs for Electronic Engines	3-6
Table 3-8. Differential Engine Modifications Costs to Meet Tier III Emission Levels	3-7
Table 3-9. Fumigation Costs	3-8
Table 3-10. Fumigation Water Tank Costs	3-9
Table 3-11. Fumigation Distilled Water Costs	3-9
Table 3-12. Fuel Emulsification Costs	3-10
Table 3-13. Emulsification Water Tank Costs	3-11
Table 3-14. Emulsification Distilled Water Costs	3-11
Table 3-15. Direct Water Injection Costs	3-12
Table 3-16. DWI Water Tank Costs	3-13
Table 3-17. DWI Distilled Water Costs	3-13
Table 3-18. Exhaust Gas Recirculation Costs	3-14
Table 3-19. Sludge Tank Costs	3-15
Table 3-20. Selective Catalytic Reduction Costs	3-16
Table 3-21. Urea Tank Costs	3-17
Table 3-22. Urea Costs	3-17
Table 3-23. Sea Water Scrubber Costs	3-18
Table 3-24. Sludge Tank Costs	3-19
Table 3-26. Case 1  Fuel Switching Costs (New Construction)	3-20
Table 3-27. Additional Fuel Tank Storage Costs	3-21
Table 3-28. Case 2 Fuel Switching Costs (Retrofits)	3-22
Table 3-29. Hourly fuel use  change estimated for a one percent change in brake specific fuel consumption	3-23
ICF International                                   M                 U.S. Environmental Protection Agency
EPA Contract EP-C-06-094, WA 2-08                                                               April 20099

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1.    Introduction

In December 2007, EPA published an Advanced Notice of Proposed Rulemaking to enact more
stringent exhaust emission standards for engines on ocean going vessels.1  New NOx and SOx
exhaust emission standards were discussed for engines on Category 3 marine vessels.2

Two new tiers of NOx standards  have recently been adopted by the I MO.  Tier II NOx standards
are roughly 20 percent lower than the  existing  Tier I NOx  standards set by the International
Maritime Organization in  Annex VI.3  To meet these standards,  in-cylinder emission control
approaches  such  as electronically  controlled high  pressure common  rail  fuel systems,
turbocharger optimization, compression ratio changes and electronically controlled exhaust
valves could be used.  Tier III NOx standards which only apply in designated Emission Control
Areas  are  roughly  80 percent below Tier  I NOx standards and would likely require exhaust
aftertreatment such as selective catalytic  reduction (SCR).   Other  approaches that may be
considered  to reduce NOx  emissions from Category  3 vessel engines are  exhaust gas
recirculation and water technologies such as direct water injection or fumigation.

In addition  to these NOx standards for new Category 3 marine vessel engines, standards were
adopted by the IMO for NOx  limits for existing engines due to the very long life of ocean  going
vessels and the availability of known in-cylinder technical modifications such as slide valve fuel
injectors and injection timing retard that provide significant and cost-effective NOx reductions. It
is believed that engines  built in  1990  through 1999 are compatible with these  lower NOx
components.  The standards require that engines  would need to be modified to achieve a 20
percent reduction in NOx emissions from their existing baseline emission rates.

Reductions in SOx and PM are expected to be met primarily through two approaches. The first
would  be to operate the engines on a lower sulfur distillate fuel.   Category 3 marine engines
typically operate on heavy fuel oil with a sulfur content of 2.7 percent. Significant SOx and PM
reductions  could  be achieved using distillate  fuels with a sulfur content of 0.1  percent.  Fuel
costs will be estimated through a separate effort.  However, costs due to vessel modifications
will be considered here.  For instance, if a lower sulfur fuel  is used only  near U.S.  coasts, the
vessel must be capable of switching between  heavy fuel oil and distillate  fuel.  In the case of a
vessel converting exclusively to distillate fuel, cost  savings may  be achieved  with a greatly
simplified fuel treatment system on board the  vessel.  Alternatively,  the vessel could  continue to
operate on high sulfur fuel if it were equipped with an exhaust gas scrubber to remove SOx from
the exhaust.

This report includes descriptions of baseline and likely emission control technologies expected
to be used to meet Tier II  and Tier III emission standards, the lower  sulfur fuel requirement for
designated Emission Control Areas, as well  as the related costs for application, usage, and
maintenance of these technologies.
1  Environmental Protection Agency, "Control of Emissions from New Marine Compression-Ignition Engines at or
  Above 30 Liters per Cylinder; Proposed Rule," Federal Register/Vol. 72, No. 235/Friday, December/, 2007.
  Available at http://www.epa.qov/fedrqstr/EPA-AIR/2007/December/Dav-07/a23556.pdf
  Category 3 marine vessel refers to ocean going vessels which have at least one Category 3 marine diesel engine
  with a displacement of at least 30 liters per cylinder.  The standard will apply to all engines on a Category 3 marine
  vessel including auxiliary engines which are typically Category 2 (5 to 30 liters per cylinder).
3  Annex VI of MARPOL 73/78: Regulations for the Prevention of Air Pollution from Ships and NOx Technical Code
  from the IMO (ISBN 92-801-6089-3) (IMO Sales Number IMO-664E)
ICF International                              1-1                 U.S. Environmental Protection Agency
EPA Contract EP-C-06-094, WA 2-08                                                        April 20099

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          Costs of Emission Reduction Technologies for Category 3 Marine Engines
                                       Introduction


                             Figure 1-1. Proposed IMO Standards
        20

        18

        16

        14

       •12
         6

         4

         2

         c;
Tier
             Tit
             Tier I
    n < 130 rpm -* 17.0 g/kWh
130 < n < 2000 rpm ^ 45 x n*3 g/kW
   n < < 2000 rpm -» 9.B g/kWh
                                          Tier II
                                 n < 130 rpm -+ 14.36 g/kWh
                             130 < n< 2000 rpm -» 44 x n M g/kWh
                                n < < 2000 rpm ^ 7.668 g/kWh
                                Cofresponds to 80% reduction of Tier I
             0    200   400  600   800   1000  1200 1400 1600  1800 2000 2200

                                    Rated engine speed (rpm)
     Source: MAN Diesel SE
4 MAN Diesel, "Exhaust Gas Emission Control Today and Tomorrow," August 19, 2008, available at
  http://www.manbw.com/article 009187.html
ICF International
EPA Contract EP-C-06-094, WA 2-08
                        1-2
         U.S. Environmental Protection Agency
                              April 20099

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2.    Technology Description
Category 3 marine diesel engines are currently being built to meet Tier I IMO MARPOL Annex
VI emission standards.  A brief description of the baseline technologies is given below as well
as descriptions of the various technology improvements used to obtain lower emission levels.

2.1.  Baseline Technologies

Current engines built to meet  MARPOL  Tier  I emission  levels  are considered  baseline
technologies for this analysis. Generally Tier I NOx emission levels are estimated as 11 percent
below Tier 0 emission levels.5  Engine modifications currently being used by manufacturers are
listed in Table 2-1. To assess the costs of new technologies needed to reduce emissions below
future MARPOL levels, average engine characteristics have been defined.  In order to account
for different technology costs that are associated with different size and/or types of engines, a
number of 'average  engines' were developed;  these engines with  'typical' characteristics are
listed in Table 2-2.   Both low-speed and medium-speed Category 3 engines are represented.
Estimated costs would need to be adjusted for larger or smaller engines of each type.

       Table 2-1. Engine Modifications Currently In-Use to Meet MARPOL Emission Levels6
Component or
Operation Changed
turbocharger
Intercooler
air inlet port
cylinder head
piston crown
injection pressure
injectors
nozzle
injection timing
exhaust valve timing
Change
improved efficiency,
schemes for variable flow
improved efficiency
redesigned shape
redesign shape
redesigned piston crown
shape
increase
redesign
smaller holes, more holes,
cleaner holes, etc.
retard and/or vary with
load
"Miller cycle" timing
Parameter Affected
SFC, intake pressure
air inlet temperature
swirl
swirl, compression ratio
swirl, compression ratio
atomization
sac volume, injection
rate shaping
spray pattern changes
peak cylinder
temperature
peak cylinder
temperature
Low-Speed
Engines
yes
yes
maybe
maybe
no
yes
yes
possibly
yes
yes
Medium-Speed
Engines
yes
yes
yes
yes
yes
yes
yes
yes
yes
yes
5 Conversation with Michael Samulski of EPA, May 2007.
6 Melvin Ingalls and Steven Fritz, "Assessment of Emission Control Technologies for EPA Category 3 Commercial
  Marine Diesel Engines," Southwest Research Institute Report, September 2001.
ICF International
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U.S. Environmental Protection Agency
                 April 20099

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          Costs of Emission Reduction Technologies for Category 3 Marine Engines
                                Technology Description


                 Table 2-2. Average Engine Characteristics Used in this Study
Engine Type
Engine Power (kW)
Cylinders
Liters/cylinder
Engine Speed (rpm)
BSFC (g/kWh)
Medium-Speed
4,500 9,500 18,000
9 12 16
35 65 95
650 550 500
210
Low-Speed
8,500
6
380
130

15,000 48,000
8 12
650 1400
110 100
195
2.1.1.   Low-SpeedEngines

Low-speed engines are usually two-stroke  engines with large displacements  up to 2000
L/cylinder and are used for propulsion on bulk carriers, container ships, larger tankers, general
cargo and roll-on/roll-off ships. They are typically turbo-charged with aftercooling and have four
exhaust valves per cylinder.  Scavenge air enters the cylinder through a series of intake ports
arranged around the bottom of the cylinder.  Intake is controlled by the piston as it uncovers or
covers the intake  ports.  Fuel injection is typically mechanical with 3 injectors per cylinder. They
typically have 4 to 20 cylinders.

2.1.2.   Medium-Speed Engines

Medium-speed engines  are usually four-stroke  engines  with  significantly smaller  cylinder
displacement  (30  to 200 L/ cylinder)  than low-speed engines.  They  are typically used  as
propulsion engines on smaller tankers,  general cargo,  roll-on/roll-off ships, ferries, cruise ships,
and  as  auxiliary  engines on large  ships  for power generation or refrigeration.   They are
commonly turbo-charged and aftercooled, have two intake and two exhaust valves per cylinder
and  are  mechanically  injected  with  one injector per cylinder.  They typically have 6 to  18
cylinders.

2.1.3.    Typical Ship Characteristics

In order  to better understand various  ship types as they approach  U.S.  ports,  average ship
characteristics were determined for each ship type based  upon the 2002 Category 3  Marine
Vessel Port Inventory.7  This information is used to determine  average time per port call  as well
as average auxiliary to propulsion power ratios.
  ICF International, "Commercial Marine Port Inventory Development-2002 and 2005 Inventories," September
  2007. Available at
  http://www. regulations.qov/fdmspublic/ContentViewer?obiectld=090000648037139b&disposition=attachment&cont
  entType=pdf
ICF International
EPA Contract EP-C-06-094, WA 2-08
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U.S. Environmental Protection Agency
                    April 20099

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          Costs of Emission Reduction Technologies for Category 3 Marine Engines
                               Technology Description


                    Table 2-3. Average Ship Characteristics by Ship Type
Ship Type
Auto Carrier
Bulk Carrier
Container
General Cargo
Passenger
Reefer
RoRo
Tanker
Average
Average
Propulsion
Power
(kW)
11,155
8,350
26,211
6,709
34,800
10,060
11,687
9,667
15,244
Service
Speed
(knots)
18.7
14.5
21.6
15.2
20.9
19.5
16.8
14.8
17.4
Auxiliary
Power
Ratio8
0.266
0.222
0.220
0.191
0.278
0.406
0.259
0.211
0.227
Average
Auxiliary
Power
(kW)
2,967
1,854
5,747
1,281
9,674
4,084
3,027
2,040
3,533
2002
Calls
3,306
9,600
14,703
7,391
3,623
1,447
2,137
13,310
55,517
Average auxiliary engine load factors and average hotelling time by ship type are given in Table
2-4 for ships calling on U.S. ports in 2002.

      Table 2-4. Average Auxiliary Engine Load Factors and Hotelling Times by Ship Type
Ship Type
Auto Carrier
Bulk Carrier
Container
General Cargo
Passenger
Reefer
RoRo
Tanker
Average
Auxiliary Load Factors
Cruise
13%
17%
13%
17%
80%
15%
20%
13%
19%
Transit
30%
27%
25%
27%
80%
30%
34%
27%
30%
Maneuver
67%
45%
50%
45%
80%
45%
67%
45%
51%
Hotel
24%
22%
17%
22%
64%
30%
34%
67%
35%
Hotel
(hrs)
45.0
88.0
48.0
88.0
11.0
60.0
45.0
38.0
55.5
2.2.  Advanced Technologies

Technologies that can be used to meet Tier II and Tier III emission levels are discussed in this
section along with those that would be used to retrofit engines built between 1990 and 1999 to
meet Tier I emission levels.

2.2.1.   Tier I Retrofit Technologies

The October 2008 amendments to MARPOL Annex VI include regulations on ships constructed
on or after January 1, 1990 but prior to January 1, 2000 for marine diesel engines with a per
cylinder displacement of at least 90 liters and with a power output of over 5,000 kW. Such
engines must be retrofit and be certified confirming the engine meets Tier I standards. Most
manufacturers will comply with the regulation by providing  retrofit kits which contain modified
  Ratio of total auxiliary engine power to total propulsion power. These were determined from a survey of 327 ships
  in January 2005 by the California Air Resources Board.
ICF International
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U.S. Environmental Protection Agency
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          Costs of Emission Reduction Technologies for Category 3 Marine Engines
                                Technology Description


fuel injectors and possibly modified injection timing.  Approximately all Category 3 ships with
slow speed diesel engines constructed between 1990 and 1999 have engines with over 90 liters
per cylinder while approximately 35 percent of Category 3 ships with medium speed diesel
engines constructed between 1990 and 1999 have engines with over 90 liters per cylinder.

Retrofit kits for slow speed diesel engines will include low-NOx slide valves. Slide valves have
zero sac volume so fuel dribbling into the engine cylinder after injection is minimized.  This leads
to lower HC and CO emissions as well as lower PM  emissions because any fuel that dribbles
into the engine cylinder after combustion will tend  not to burn completely. In addition, low-NOx
slide valves have optimized  spray patterns which minimize NOx formation. Low-NOx slide
valves have been shown to  reduce NOx from 20 to 25 percent with a 1  to 2 percent fuel
consumption penalty.9

Retrofit kits for medium speed engines would likely include injectors modified for low NOx
performance and injection timing retard.  By locating the flame zones closer to metal surfaces
(cylinder head, piston) NOx  can be reduced in medium speed engines.10  Cooling of the flame
and/or burnt gases by surfaces reduces NOx. Too much cooling, or impingement of unburnt fuel
on metal surfaces would increase smoke. By changing the spray cone angle, NOx can also be
reduced. It is expected that NOx optimized nozzles  could provide a 20 to 25 percent drop in
NOx with in a 1  to 2 percent fuel consumption penalty.

2.2.2.  Tier II Technologies

Most engine manufacturers can reach Tier II levels  with engine modifications.   Some of the
older mechanically injected  engines  will  be replaced with common rail fuel injection systems.11
However, it is estimated that approximately 20 percent of low speed engines and 60 percent of
medium speed engines  may  still  be mechanically  injected.   Engine  modifications  include
retarded fuel injection timing, higher compression ratios,  lower excess air ratios, lower inlet air
temperatures,  better fuel distribution, improved  nozzle  sac design,  and use of Miller cycle
valving. MAN Diesel estimates a 4 to 6 g/kWh increase in specific oil fuel consumption (SOFC)
to meet Tier II regulations.11

2.2.2.1   Fuel Injection Timing

By injecting later in the engine cycle, maximum cylinder pressure is reduced, thereby lowering
peak cylinder temperatures and thus  NOx production.  However,  lowering maximum cylinder
pressure also reduces engine efficiency and increases particulate emissions.  In one instance,
by retarding the injection by 2° crank angle,  cylinder  pressures were reduced  by  about 10 bar
and  NOx  emissions were  reduced by about 10  percent;  however, fuel  consumption was
increased by about 1.5 percent.12 Maximum NOx reductions through this method  are about 25
percent, but can be limited by turbocharger speed, because more energy escaping the exhaust
will  provide more energy to the turbocharger, thereby increasing cylinder pressures.
  Goldsworthy, L, "Design of Ship Engines for Reduced Emissions of Oxides of Nitrogen," in Engineering a
  Sustainable Future Conference Proceedings. July 2002. Available at
  http://www.amc.edu.au/svstem/files/shipNOx.pdf
10 Paro, D., "Development of the Sustainable Engine," 23rd CIMAC Congress, 2001.
11 MAN Diesel, "Exhaust Gas Emission Control Today and Tomorrow," August 19, 2008," available at
  http://www.manbw.com/article 009187.html
12 Geist et al., "Marine Diesel NOx Reduction Technique- A New Sulzer Diesel Ltd Approach," SAE paper 970321.
ICF International                              2-6              U.S. Environmental Protection Agency
EPA Contract EP-C-06-094, WA 2-08                                                      April 20099

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          Costs of Emission Reduction Technologies for Category 3 Marine Engines
                               Technology Description


Retarding fuel injection timing also increases the exhaust temperature. Exhaust valves need to
be kept below 450°C to  prevent excessive damage and short operational life.  In many cases,
exhaust valves  are additionally cooled and exhaust valve faces are clad with erosion-resistant
materials. Higher grade cylinder liners are used to reduce wear.  Pistons are also additionally
cooled with oil jets and clad to prevent hot spots and piston damage.

2.2.2.2   Higher Compression Ratio

The effective compression ratio  of an engine can be increased  by increasing the  geometric
compression  ratio by installing piston rod shims, varying the valve timing or by increasing the
scavenge air  pressure. Raising compression ratio generally increases NOx while reducing PM
and BSFC. When higher compression ratios are  used with fuel injection timing  retard, the
compression pressure increase due to combustion is minimized and thereby NOx emissions are
reduced. Varying valve timing or increasing the scavenge air pressure; however, influence the
excess air ratio so NOx  formation rates are affected as well (see  Section 2.2.1.3 below).  The
maximum achievable  NOx reductions of 25 percent from  fuel injection timing retard can be
achieved without a fuel consumption penalty if the compression ratio is raised. The maximum
compression ratio is limited by the structural strength of the engine. Additional strengthening of
the rods, crankshaft,  piston,  head,  and cylinder liner are  sometimes needed to handle the
additional combustion pressures and temperatures.

2.2.2.3   Excess Air Ratio

Oxygen concentration in the  fuel/air mixture affects NOx emission formation.  Lowering the air
excess ratio from 2.2  to 1.9  by adjusting the valve timing and compression ratio at the same
time to keep the effective  compression ratio constant can reduce NOx emissions by about 15
percent and result in  a  slight reduction  in fuel consumption12  Lowering the excess  air  ratio
increases the thermal load on the engine, thereby limiting the amount of NOx reduction possible
from this method.

2.2.2.4   Inlet Air Temperature

By lowering the scavenge air temperature, NOx emissions can be  decreased.  In most engines,
the scavenge air temperature is  limited by the cooling water temperature.   However, use of a
separate circuit aftercooling  system  (which  utilizes an additional  heat  exchanger  for the
aftercooler) can further reduce the  air temperature and provide substantial reductions in  NOx
emissions while providing a reduction in fuel consumption. Some engines already use separate
circuit aftercooling, while others install the aftercooler prior to the engine cooling circuit, ensuring
it receives cooler water  than the after the engine water jacket.   Separate circuit aftercooling
provides larger benefits than just plumbing the aftercooler first  in the  engine cooling circuit
because lower inlet temperatures can be achieved with separate circuit aftercooling.

2.2.2.5   Fuel Distribution

Fuel distribution in the cylinder is influenced by intake air swirl,  the number of injection nozzles,
the fuel spray pattern, droplet size and to a lesser degree,  injection pressure.  The interaction
between the sprays from individual  nozzle holes has a significant  impact on NOx. There exists
an optimum number of nozzle holes for minimum NOx. In addition the angle of the spray cone
can also affect  NOx.  By directing the spray near the piston, there is less air entrainment in the
earlier stages of injection leading to lower NOx emissions.  This can also enhance turbulence
and  mixing  during  the   latter   stage  of combustion  which  reduces emissions  and  fuel
ICF International                              2-7             U.S. Environmental Protection Agency
EPA Contract EP-C-06-094, WA 2-08                                                      April 20099

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          Costs of Emission Reduction Technologies for Category 3 Marine Engines
                                Technology Description


consumption.  NOx reductions of 30 percent have been achieved in some engines, but in most
cases there is a strong trade-off between NOx reductions and fuel consumption.9

2.2.2.6   Nozzle Sac Design

By  reducing nozzle sac volume,  particulate  and hydrocarbon emissions are reduced.   The
nozzle sac is the small volume at the end of the nozzle that can contain trapped fuel after the
injector valve closes.  This fuel tends to dribble into the cylinder later in  the cycle and tends to
result  in  both hydrocarbon and  particulate emissions.    By eliminating  the  sac volume,
hydrocarbon emissions can be reduced up to 75 percent at full  load.13  Most low speed engines
already use slide valve nozzles to  meet Tier I emission levels.  Diagrams of nozzle sacs are
shown in Figure 2-1.

             Figure 2-1. Cross-Sectional diagrams of Different Nozzle Sac Designs
                                                                           Nov.- used as
                                                                             standard
                                                        Solid
Mini-sac
Sac 520 mm
   Slide-type fuel valve
    Sac volume 01
      Conventional fuel valve
      Sac volume 1690 mm

      Source: Man B&W14

2.2.2.7   Miller Cycle Valving

By using high pressure turbocharging and closing the intake valve before the piston reaches
bottom dead center (BDC) during the intake stroke, the entrapped air charge will be expanded
and reach the pressure of a normal turbocharged engine at BDC,  but at a significantly cooler
temperature  due to the expansion.  This leads to the bulk cylinder temperature being lower
13 Ole Gr0ne and Kjeld Aabo, "How to meet local and international marine emission legislation," presented to the
  Institute of Marine Engineers in Rotterdam, September 2001
14 Kjeld Aabo, "Marine Transport Fuels and Emissions," presented at the Third Nordic-Japan Environmental Conference in
  Nagano, Japan, November 2002.
ICF International
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U.S. Environmental Protection Agency
                    April 20099

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                                                                                   Miller
          Costs of Emission Reduction Technologies for Category 3 Marine Engines
                                Technology Description


during the  entire  combustion  process, which directly  reduces  NOx emissions.
supercharging can reduce NOx by 20% without increasing fuel consumption.9

2.2.2.8    Common Rail Injection/Electronic Fuel Injection

The common rail  refers to a rail or tube running the length of the engine below the level of the
cylinder cover.  Heated fuel is supplied to the common rail injection system at high pressure,
ready for injection.  Injection occurs under constant fuel pressure via electronic/hydraulic high-
pressure pumps running on multi-lobe cams.

One manufacturer's heavy fuel common rail system  is constructed from  a series of  inter-
connected accumulators.  Each common rail injection  pump supplies two accumulators.  The
design can be retrofitted to existing engines by simply removing the current injection pumps and
replacing them with a  common rail delivery pump and an  accumulator.  Each accumulator is
connected directly to two injectors and each line contains a flow fuse for safety. A flow control
valve regulates the rail pressure on each of the rail  pumps.  The regulation signal to the flow
control valve comes from the electronic control system.  The fuel oil injection timing and duration
are electronically controlled as well.  High pressure engine lubricating oil is used to open the fuel
injection valve.

NOx reductions from common rail  systems are mostly  due to the ability to control the amount
and rate of fuel injection at low loads as opposed to mechanical injection systems.  Mechanical
systems  generally do  not have the  flexibility to  provide the right amount of  fuel for all  load
settings.  Because the  right amount  of fuel  can be  injected  at all loads, fuel consumption is
reduced.  Outside of its utility for NOx reductions, this technology also reduces visible smoke
from unburned excess fuel from cruise ships because it  limits over-fueling during maneuvering.

This technology is currently being  demonstrated on a low-speed diesel engine constructed by
Sulzer, called the Sulzer R-T flex engine. It has been estimated that use  of the Sulzer R-T flex
engine, and  its common-rail fuel injection system, can provide 20% lower NOx emissions over
current Tier  I standards. Table 2-5 presents key features and benefits of the Sulzer design.15 A
diagram of a Wartsila common rail system is shown in Figure 2-2.16
15 Stefan Fankhauser, "World's first common-rail low-speed engine goes to sea," Marine News, No. 3-2001, pg 12-15
16 Wartsila Corporation, "Wartsila Common Rail - A Super Efficient Fuel Injection System,"  February 2007, available at
  http://www.wartsila.com/Wartsila/qlobal/docs/en/about us/twentvfour7/2 2007/common rail injection system info
  qraphics.pdf
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        Table 2-5. Key Attributes and Benefits to the Sulzer RT-flex Common Rail System
    Key Features
  System Benefits
     o   Precise volumetric control of fuel
        injection, with integrated flow-out
        security
     o   Variable injection rate shaping and free
        selection of injection pressure
     o   Ideally suited for heavy fuel oil
     o   Proven, high-efficiency supply pumps
     o   Lower levels of vibration and internal
        forces and moments
     o   Steady operation at very low running
        speeds with precise speed regulation
  o   Reduced maintenance requirements
  o   Full electronic common-rail control with
      integrated monitoring functions
  o   Better fuel economy (currently due mainly to
      part-load operation)
  o   Easier compliance with the NOx emission
      limit in Annex VI of the MARPOL 73/78
      convention
  o   Lower steady running speeds, down to 12
      rpm
  o   No visible smoke at any operating speed
                     Figure 2-2. Wartsila Common Rail Fuel Injection System

                            Accumulator
                  Low pressure
                    Fuel Feed
       SSV (Start-up and Safety Valwl


                   Injector
                                                                          ,,NC
                Fuel
               Return
                Pump
               (Camshaft
                Driven)
                 Camshaft
                                      Common Rail
        Source: Wartsila Corporation
                               15
                                                  Crankshaft Speed Sensor
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A second manufacturer has installed an  electronically  controlled cam-less engine using an in-
house developed electronic-hydraulic platform on a 37,500 DWT deep sea chemical carrier.17
The system allows for electronically controlled fuel injection and exhaust valve actuation which
permit individual  and continuous adjustment of the timing for each  cylinder.   Parts that are
removed from the mechanical system include the chain drive for camshaft, camshaft with fuel
cams, exhaust cams and indicator cams, fuel pump actuating gear, including roller guides and
reversing mechanism, conventional fuel injection pumps, exhaust valve actuating  gear and  roller
guides, engine driven starting air distributor, electronic governor with actuator, regulating shaft,
mechanical  engine driven  cylinder lubricators, and  engine side  control  console.  The  items
added to the engine include a hydraulic power supply, hydraulic cylinder unit with electronic fuel
injection  and  electronic  exhaust  valve   activation,   electronic  alpha  cylinder  lubricator,
electronically controlled starting valve, local control  panel, control  system with  governor,  and
condition monitoring system. Two electronic control units  are used to control the system with
one being a backup for the first.  The manufacturer claims that the electronic  version of the
engine was  very easy to adjust to the prescribed setting values and was able to keep the very
satisfactory  setting values without further adjustments since the vessel's sea trials in November
of 2000.

A third manufacturer has further developed  mechanically-actuated electronically-controlled unit
injectors and hydraulically actuated electronically-controlled unit injectors to provide the flexible
fuel injection characteristics needed  to optimize engine performance and emissions.18   The
manufacturer states that the design  approach in both injector concepts is to utilize a Direct
Operated Check (DOC) to precisely control the pressure, timing and delivery of fuel. The  DOC
is applicable to electronic  unit  injector or unit  pump configurations with  either  mechanical or
hydraulic actuation of the  pressurizing units.   The manufacturer has claimed the technology
eliminates spray distortion  and  minimizes parasitic losses  which may be seen in common rail
fuel systems.   The manufacturer  includes discussion  on  closed loop NOx  control  in the
reference paper.  They state that ultra fast NOx sensors are a key part to closed-loop control of
NOx emissions.  The sensors  provide the benefits of minimized engine to engine variations,
minimized  cylinder to  cylinder  variations  and improved  transient  response  with reduced
emission and reduced operational costs.

2.2.3.  Tier III Technologies

Tier III emission levels will require large  reductions in  NOx and SOx emissions. Most engine
manufacturers believe they will use SCR in combination  with lower sulfur marine diesel oils
(MDO)  or marine gas oils  (MGO) to meet Tier III standards.  However, other  NOx reduction
techniques include introduction  of water into  the combustion chamber either through fumigation,
fuel emulsions or direct water  injection and exhaust gas  recirculation. .  In fact,  Viking Line
produced simillar NOx reductions to SCR using a HAM system as shown in Figure 2-3.19 While
SCR outperformed the HAM system on all five ships, the reductions were close.  With EGR and
a HAM system, NOx reductions approaching those for SCR  could be achieved.
17 Sorensen.Per andPedersen, Peter, "The Intelligent Engine Design Status and Service Experience," International
  Council on Combustion Engines, CIMAC Congress 2001
18 Moncelle, M.E., "Fuel Injection System & Control Integration," International Council on Combustion Engines,
  CIMAC Congress 2001.
19 Presentation of Ulf Hagstrom, Marine Superintendent, Technical sector, Viking Line Apb, "Humid Air Motor (HAM)
  and Selective Catalytic Reduction (SCR) Viking Line," at Swedish Maritime Administration Symposium/Workshop
  on Air Pollution from Ships (May 24-26, 2005)
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          Costs of Emission Reduction Technologies for Category 3 Marine Engines
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                       Figure 2-3. Comparison between SCR and HAM
  VIKING LINE
COMPARISION BETWEEN SCR & HAM
REDUCTION of Noi DUREN'G ONE YEAR
    WITH TODAYS SCHEDULE
  I
  I






30




nSCR
DHAM
























AMORELLA. ISABELLA
90
75













ROSELLA
SO
74




















CiABRTFT T A
SS
S2













M.ARIFT.T.A
91
82













CINDERELLA
82
75
                                           SHIP

Other techniques to reduce emissions will include compound or two-stage turbocharging as well
as electronic valving to enhance performance and  emission  reductions.   To meet  low SOx
requirements, shipping fleets will either use sea water scrubbers or fuel switching to lower sulfur
fuels or run full time on lower sulfur fuels.

2.2.3.1    Engine Modifications

Engine modifications to meet Tier III emission levels will most likely include a higher percentage
of common  rail fuel injection systems  coupled  with the use of two-stage  turbocharging and
electronic valving.  Engine manufacturers estimate that practically all low speed engines and 80
percent of medium speed engines will use common rail fuel injection. Two stage turbocharging
will probably be installed on at least 70 percent of all engines produced to meet Tier III  emission
levels.  Electronically  (hydraulically) actuated intake and exhaust  valves  for medium speed
engines and electronically actuated exhaust valves  for low speed  engines are  necessary to
accommodate two-stage turbocharging.

Two-stage turbocharging is set up in various fashions. The most popular set up  is to use one
smaller and one larger turbo. The larger turbo's compressor stage blows into the  smaller one's
compressor stage. The exhaust is set up the other way round:  it first enters the turbine  of the
smaller turbo, and then the turbine of the larger turbo. Two-stage turbocharging systems were
shown to improve considerably the performance of four-stroke engines, showing potentials for
reducing  NOX emissions by up to 50 percent at certain load ranges together with some savings
in fuel consumption. Good part-load performance was ensured by  using a  variable inlet valve
closure (VIC) system which  enables the Miller effect to be varied according to  engine  mean
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effective pressure  (BMEP).20  Electronically actuated valves allow variable intake and exhaust
valve opening and  closing which enhances the Miller effect.

2.2.3.2   Fumigation

There are currently three types of fumigation systems, namely the Humid Air Motor (HAM), the
Scavenged Air Moisturizing (SAM) system and the Wetpac H.

 The HAM process was developed by Munters Europe AB,  and has undergone trials for 4000
hours on the  MS Mariella in the Viking Line. The  HAM system uses heated charge air enriched
with evaporated seawater to reduce NOx emissions during the combustion process.  The HAM
system is used to replace the conventional engine air intercooler.  Since it uses engine heat to
heat the seawater,  additional boiler capacity may be needed for other ship needs.

The central part of the HAM system is a special  humidification unit, which is effectively a heat
exchanger. This must be mounted very near the  engine. Other equipment include a circulation
pump and filter, a heat exchanger (to heat the incoming water), a "bleed-off" system (to control
the contents of salt and minerals in the water) and a water tank as shown in Figure 2-3.
                                 Figure 2-4. HAM System


                       Compressor      I              I     |  Turbine
                  HAM Unit
                          Pump

                  Source: Viking Line19

Water, which has already been heated by the engine cooling system, is additionally heated and
vaporized using hot air from  the turbocharger. This humidified charge air is directed into the
combustion chamber after filtration for debris. The system has been reported to reduce NOx by
70-80% with water to fuel ratios of 2.8 at normal operating speeds and  loads.21  While MAN
B&W has tested HAM units on smaller engines typically on ferries, no tests to date have been
done on engines the size used on container or bulk carrier vessels.

In contrast to SCR, no warm-up time is necessary with HAM and NOx reduction commences
more or less once the motor is engaged. As  a precaution to minimize possible corrosion in the
20 Wartsila Corporation, "Joint diesel research project completed," Trade & Technical Press release, 6 September
  2007 available at http://www.wartsila.com/ch,en,press,0,tradepressrelease,3D5201D4-5D37-4E26-B7E8-
  D4E6F592CE6A,5B771063-161A-4942-810E-5329B81B3565,,.htm
21 Peter Mullins, "The H.A.M. System Approach to Reducing NOx," Diesel & Gas Turbine Worldwide. November
  2000.
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humidification  unit, it is advised that the water flow is turned off around  15 minutes before
engine shut down to dry out the exhaust tower. Although MS Mariella operates using a lower
sulfur heavy fuel oil (IF  220), an additional claimed advantage over SCR is that HAM is suitable
for residual oils with higher sulfur contents of up to 4.5 percent.22

The SAM system is being developed by MAN B&W and has been tested on the MA/ Mignon of
the Wallenius-Wilhelmsen  Lines.  The SAM installed on a B&W 8S60MC engine on the MA/
Mignon has a sea water injection stage, where a surplus of sea water is injected for saturation
and cooling of the hot air from the compressor. The sea water (SW) stage provides nearly 100%
humidification of the scavenge air and supplies all of the water for humidification.11  The SAM
system is shown in Figure 2-4.  The SAM components in the compressor air cooler arrangement
(i.e. SW spray, transition piece, S-bend and inlet box for the fresh water stages [FW1 and  FW2])
are manufactured in  austenitic stainless 254SMO because  of its excellent resistance against
corrosion from salt water.

                                 Figure 2-5. SAM System
         SW Spray Unit
         Transition piece

         S-bend for separation
         of residue SW

         SW mist catcher

         Box with FW1
         and FW2 stages
        Air Cooler with
        Water Mist Catcher
                                                            Sea Water Inlet
                 Sea Water Outlet

                  FW Stagel Inlet
                 FW Stagel Outlet
                  FW Stage2 Inlet
                                                          FW Stage2 Outlet
    Source: MAN B&W
                  .11
The Wetpac H is developed by Wartsila. The principle of Wetpac H technology is to introduce
pressurized water into the combustion process to reduce NOx formation. The pressurized water
is added to the intake air after the turbocharger compressor. Due to the high temperature of the
compressed air, the water evaporates immediately and enters the  cylinders  as steam, thus
lowering the combustion temperatures  and the formation of NOx. Wetpac H technology has so
far been developed for the Wartsila 20, 32 and 46 engine types, and the first  pilot installation
was  commissioned in  2003. The  anticipated  NOx reduction  is up  to 50%,  and the water
consumption is expected to be about two times the fuel oil consumption. The Wetpac H system
is shown in Figure 2-5.
22
  Entec UK Ltd, "Service Contract on Ship Emissions: Assignment, Abatement and Market Based Instruments -
  Task 2b - NOx Abatement," August 2005 available at http://ec.europa.eu/environment/air/pdf/task2  nox.pdf
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                                 Figure 2-6. Wetpac H System
             Compressor
                                                   Evaporated water is partly re-condensing
                                                   in the charge air cooler
       Water injection 130-135 bar
     Injected water mist is evaporated
     and hot air after compressor is
     cooled to saturation point
                                 Saturated air
                                 40...70
                                                                                     °C
                                    Heat from cooling water
                                    is reducing re-condensation
                   N on-evaporated water
                   Is captured in the
                   water mist catcher and
                   re-circulated
          13 -eanarj 3XT PnKniBtw. nans.' Ajrcr,
                                                                                  WARTSILA
    Source: Wartsila Corporation
                           23
2.2.3.3    Fuel Emulsification
Another method of introducing water into the combustion chamber to reduce NOx production is
through water-in-fuel emulsions.  MAN  B&W has been testing water-in-fuel emulsions since the
early 1980s.  Formation of the emulsion is achieved within the standard fuel module, which has
to be slightly  modified.  Given that a fuel injector delivers a fixed volume of fuel for a particular
power output, the addition of water increases the volume that must be injected.   This fact
requires that  the injector assembly - specifically the atomizer design, must be adapted to the
increased injection volume. Fuel emulsification can be used on  either mechanical  or electronic
injection system. A schematic of a pressurized water emulsion system  is shown in Figure 2-6.
23 German Weisser, "Emission Reduction Solutions for Marine Vessels - Wartsila Perspective," presented at the Clean Ships -
  Advanced Technology for Clean Air Conference, February 2007. Available at
  http://www.cleanshipsconference.com/pdfs/Weisser.pdf
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                     Figure 2-7. Pressurized Fuel Emulsification System
                                                                         • r^^~-~- I IUIM
                                                                         _!	   centrifuges
   To sludge tank
             Water in oil measuring
             (MBD supply)
                                                                  Safety pump
                                                     To HFO service
                                                     or setting tank
       Source: MAN B&W
                     ,11
Water emulsion systems require modification to the fuel pump, camshaft and control system to
handle additional  water for full load operation.  A pressurized system is also needed to avoid
cavitation and boiling off in the low pressure part of the fuel system.  In addition, a water dosage
system and homogenizer is needed.  Water's higher viscosity requires the  mixture be heated
further by about 20°C to properly flow through the injection system. In addition the fuel pressure
needs to be raised to keep the water from boiling.

MAN  B&W reports no effect on specific fuel consumption.  They estimate  that  with 10%
water/fuel ratio, a NOx reduction of 10% can be achieved but the maximum reduction is about
50%.11  However, in practice NOx reduction is limited by the maximum delivery capacity of the
fuel injection pumps.  At low ratings or at low load, higher NOx reductions can be achieved.   In
addition,  water emulsification in combination with  an electronically controlled engine offers  the
following additional flexibility advantages:

   o  Optimal injection rate shaping can be achieved both without and with any water content.

   o  "Free rate shaping" allows the use of  large water amounts even  at low engine load as
      pre-injection can be  used to compensate for ignition delay.

Water-in-fuel emulsification  is currently  being  tested on an  11K90MC engine installed on an
APL container vessel. The test is expected to be finalized at the beginning of 2009.
                                  11
2.2.3.4   Direct Water Injection
Direct  Water Injection  (DWI) is another method to reduce cycle temperatures and therefore
lower NOx emissions.  This method has been under development for Sulzer low-speed engines
since 1993.  Unlike other water techniques, DWI enables water to be injected at the right time
and  place to obtain the greatest reductions in  NOx emissions.  The water is injected into  the
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cylinder  using  a fully independent,  second  common rail injection system under electronic
control.  Also in comparison to emulsification, it allows water to be injected into the  engine
without derating the engine and  allows the fuel and water to be injected  at  different times.
Injection can occur either during the  compression stroke or with fuel injection so that injection
timing can be  optimized to both  reduce  NOx and other emissions without affecting  engine
reliability. Water injection can be turned off or on without affecting fuel injection  behavior.  NOx
emissions can be reduced 50% using a 0.7 water/fuel ratio.24 Water is fed to the cylinder head
at high pressure (210-400 bar depending on the engine type).  High water pressure  is generated
in a high-pressure water pump  module.  A low-pressure pump is also necessary to ensure a
sufficiently stable water flow to the high-pressure pump.  Water entering the low pressure pump
needs to be filtered to remove all solid particles. The pumps and filters are built into a module to
enable easy installation as shown in Figure 2-7.  NOx reduction is most efficient from 40% load
and higher of nominal engine output.

DWI requires that fresh water be generated onboard the ship and stored. Currently, a 20 to 50
percent water addition is anticipated, meaning substantial quantities of water must be generated
and stored.  Fresh water generators can be heated using engine cooling water or  using steam
from an  exhaust gas economizer. In addition, there must  be  sufficient tank capacity  for the
water with the necessary handling  system.

                   Figure 2-8. DWI Unit for Pressurizing Water and injectors
Source: Wartsila Corporation25,23
24 H. Schmid and G. Weisser, "Marine Technologies for Reduced Emissions," Wartsila Corporation, April 2005.
  Available at
  http://www.wartsila.com/Wartsila/qlobal/docs/en/ship power/media publications/technical papers/sulzer/marine te
  chnoloqies for reduced emissions.pdf
25 Wartsila, "The EnviroEngine Concept," 2004.
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DWI is  one of the  technologies currently being employed by Wartsila, which has  provided
extensive information on the method, as presented in Table 2-6.

               Table 2-6. Benefits and Limitations of Wartsila's DWI Technology
Key Benefits
o NOx emissions are reduced by 50-60%
o NOx emissions when running MDO are
typically 4-6 g/kWh
o NOx emissions when running Residual
Oil are typically 5-7 g/kWh
o The engine can also be operated without
water injection, if necessary
o The engine can be transferred to "non-
water" operational mode at any load
o In alarm situations, transfer to "non-water"
mode is automatic and instant
o Space requirements for the equipment are
minimal and therefore the system can be
installed in all installations
o Investment and operational costs are low
o Ratio of injected water to injected fuel
typically 0.4 to 0.7
o Can be installed while the ship is in
operation
System Limitations
o Cannot be used at its maximum at low loads
o Increases fuel consumption
o Clean water supply needed
2.2.3.5    Exhaust Gas Recirculation

MAN  Diesel  originally tested  a simplified exhaust  gas recirculation (EGR) system which
consisted of a loop from the exhaust gas receiver that went past the last charge air cooler, but
connected just before the last water mist catcher on a low speed engine.  This was thought to
prevent fouling of sensitive engine  parts due to high particulate and sulfur  oxide levels in the
exhaust from  burning residual oil.   It was originally thought that cleaning the  exhaust was
necessary to prevent fouling of the air cooler and receiver components.  The system had two
water injection stages with a  simple water separator unit after both.   The tests showed a
substantial  NOx reduction but confirmed that the exhaust gas could not be cleaned sufficiently
before entering the air cooler and scavenge air system. More recently, MAN diesel tested EGR
with a scrubber and water treatment, obtaining a 70 percent reduction in NOx emissions with a
relatively small increase in brake specific fuel consumption  (BSFC).11  MAN  diesel  used an
EcoSilencer® to clean the  exhaust gas  before reintroducing it into the air  cooler and scavenge
air. The scrubber removed 90  percent of the PM emissions and 70 percent  of the SOx with no
water carry over. The EGR scrubber is shown in Figure 2-8.
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                            Figure 2-9. MAN Diesel EGR Scrubber
                                     Source: MAN B&W
2.2.3.6   Selective Catalytic Reduction

The Selective Catalytic Reduction (SCR) process involves injecting a reagent, such as ammonia
or urea, into an exhaust flow, upstream of a reactor, to reduce NOx compounds into nitrogen
and water. The system  effectiveness is strongly dependent on the type of catalyst and  the
reactor temperature which generally needs to be from 210°C to 500°C.26 For 4-stroke engines
with relatively high  exhaust temperatures, the reactor unit can be placed downstream from  the
exhaust manifold as shown in Figure 2-9.  Main system components are:  an SCR reactor,
aqueous urea injection/dosing, and monitoring/control systems. The SCR system does require
storage of urea solution on-board in a separate tank.

In order to control ammonia slip (urea that is not used in the SCR unit, escaping to the exhaust)
and reach optimal  operation of the SCR unit, temperatures, pressures,  and other parameters
need  to be  carefully monitored and controlled.  In addition, the  urea injected into the exhaust
stream before the SCR reactor, needs to be well mixed with the exhaust gases before entering
the reactor for optimal performance.
26 The minimum temperature of 210°C requires 1000 ppm sulfur fuel. The minimum rises to approximately 300°C when 2.5
  percent sulfur residual oil is used. While the SCR reactor can handle temperatures of 500°C, engine manufacturers tend to
  limit exhaust temperatures to 450°C to protect valves from fouling due to vanadium and sodium present in residual oil.
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      Figure 2-10. Example of Urea SCR System for a 4-stroke engine with the reactor placed
                                 downstream of turbocharger
                               Coinsact SCR
                                        Aqueeua U'*a inaction
       Aqueous Urea
       Solution Sloraoe Taik
    Source: Wartsila Corporation

Low-speed and large medium-speed engines operate at relatively low exhaust temperatures
such that the SCR reactors need to be located between the turbocharger inlet and the engine's
exhaust manifold in order to get enough heat (see figure below).
27 http://www.wartsila.com/Wartsila/qlobal/docs/en/service/Leaflets/enviro/COMPACT SCR.pdf
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          Figure 2-11. Urea SCR system with Reactor Installation before Turbocharger
    Sulzer
    6RTA52U
    with
    SCR
    system
    Source: Wartsila Corporation23

The urea SCR systems have  successfully been used for large stationary source applications
where loads  are  fairly constant. In the marine sector, a  majority  of the installations of SCR
technology have taken place on smaller four-stroke engines as opposed to the larger two-stroke
main engines. There are more than 300 marine SCR systems currently in operation developed
by Argillon, Wartsila, Munters, and  other companies.  In certain marine engine applications, this
technology can be used in conjunction with a diesel oxidation catalyst to reduce PM emissions.

There  are  reports that a properly  designed Urea  SCR  system can reduce NOx emission by
more  than 98%  but this  is  most  likely  with significantly lower sulfur fuel.  Clean Diesel
Technologies  is one company that markets  diesel exhaust  aftertreatment technologies  for
various applications including marine and  claims  that typical NOx  conversion efficiency is
between 70  to 90  percent in  reactors that maintain  temperatures above 320°C28. Argillon
consistently reports  that their best  designs can  maintain 95 percent efficiency under  most
conditions.29   Most  companies  suggest that  for  analysis purposes  90 to 95  percent NOx
reduction efficiency can be assumed for properly designed systems.

In addition to operating temperature sensitivity to  high sulfur fuels, high  sulfur fuels can also
create large amounts of SOx which keep urea SCR reactors from operating effectively.  Sulfur
oxides can react with oxygen in the exhaust and form sulfuric acid, which can cause  corrosion
and reduce SCR system  life.  Also high levels of SOx can interfere  with  the NOx  reduction
reaction decreasing the SCR system  effectiveness. In addition if the exhaust temperature is too
low, ammonia salts will form on the  SCR unit which can essentially plug the reactor.  This is
more a problem with low speed engines than medium speed engines.  In those cases, the SCR
unit will be shut off to prevent ammonia salt formation.
28 Clean Diesel Technologies corporate website http://www.cdti.com/content/technoloqv/overview.htm
29 Argillon Website, http://www.arqillon.com/business-seqments/svstems/industrial-applications/overview.html
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2.2.3.7   Sea Water Scrubbers

Seawater scrubbing technology is designed to reduce SOx and PM emissions from large marine
and  stationary engines  situated  near a  shoreline.  The  technology uses wet  Flue Gas
Desulphurization, which is the mixing of hot exhaust flue gases with seawater.  Seawater is
alkaline by nature and rich in calcium sulfates which react well with acidic gases like SO2. The
reaction forms products which are  soluble in water and can be discharged overboard in open
sea operation. For areas where acidic water discharge is a concern, for example port operation,
the water from a scrubber is diluted with additional seawater before discharge.

Figure  2-11 provides a simplified schematic of one seawater scrubber design (by MES).   These
systems  are very effective at removing SO2 and the direct sulfate component of the exhaust
PM.  Carbonaceous PM in the engine exhaust is removed through impaction; however, much of
the carbonaceous PM can be trapped in bubbles and  may pass  through the scrubber, so PM
treatment efficiency in the seawater scrubber is  highly  dependent on the design. The captured
PM can be removed from the stream exiting the  scrubber by filtering and is kept in a settling or
sludge tank for later disposal.

   Figure 2-12. Seawater Scrubbing System with  EcoSilencer®fora "Super Yacht" design for
                                  engines up to 3.5MW
           SOOT SETTLING
               TANK    '
SEA
INTAKE

1 ^J
ENGINE \ At
          DISPOSAL
            WATER
                                                                      CLEAN
                                                                     EXHAUST
                                                                     OUTLET
                                                                 Eco Silencer
                                         30
            Source: Marine Exhaust Solutions, Inc.

While  the  scrubber  design  parameters  such  as reactor volume will  greatly  impact  its
effectiveness,  the  technology  efficiency also depends on  the  SOx concentration in engine
exhaust,  as well  as  factors such as  seawater temperature  or  salinity.   Marine  Exhaust
  Hamid Hefazi and Hamid R. Rahai, Center for Energy and Environmental Research and Services, California State
  University, Long Beach, "Emissions Control Technologies for Ocean Going Vessels," Final Report Submitted to
  State of California ARE, June 2008
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Solutions31,  a Canadian  company,  for example, claims that for engines burning up to  4.5
percent sulfur fuel, their EcoSilencer® system will reduce SO2 emissions by up to 90 percent
(higher with lower sulfur fuel). It will also eliminate up to 90 percent of visible PM  (up to 50
percent by mass), as well as reduce approximately 3 to 5 percent NOx. The company claims
that the system can be used in wide range of engines from 0.1 to 100MW.

Various scrubber designs are marketed by different companies. There are industry claims that
properly designed systems are capable of nearly complete removal of sulfur compounds from
engine exhaust, as well as up to 80 percent PM removal.32

The seawater scrubbing systems  do  result in a fuel economy  penalty in terms of  pumping power
since large amounts  of  wash water needs  to  be circulated  through  the  system.  Industry
estimates of the penalty vary but generally fall  within 1 to 3%  range depending on operating and
fuel quality conditions.

2.3.  Fuel Switching

Switching from a heavy fuel oil (HFO) with an average sulfur content of 2.7 percent to a distillate
fuel,  such as marine distillate oil (MDO)  or marine  gas  oil (MGO) with  a sulfur content of 0.1
percent,  either permanently  or temporarily, can  provide significant SOx and  PM reductions.
However in some cases,  vessel  modifications may  be necessary to achieve this,  as  it means
either migrating from the unifuel model or use of the more expensive  distilled fuel  all  the time.
The following section discusses  the systems  needed to deliver these fuels.  The next section
discusses  technical obstacles of fuel switching. The  final section  discusses modifications
needed for fuel switching.

2.3.1.    Vessel fuel systems
Some  current  marine  vessels are powered  by low-speed,  2-stroke, marine diesel  engines,
operating in  a unifuel  mode on  heavy  fuel  oil.33  Unifuel  refers to  operating essentially all
engines on the same  fuel type - typically HFO34.  Note that, in  this system,  both  main and
auxiliaries are  powered by HFO but relatively small amounts of lighter distillate  oil are also
carried for long term shutdown and emergency use.35 Prior to long term  shutdown, the engines
are operated  on distillate fuel to purge the HFO from the fuel system.

HFO contains contaminants and  other residual fuel  components that must be treated,  purified,
and/or removed and heated to  obtain appropriate viscosity onboard before  injection into  a
compression  ignition engine. Although,  generally  heavier  fuels require more complex fuel
treatment systems,  all  systems  prevent  heavy  fuel oils from solidifying in  the fuel  system,
31 Marine Exhaust Solutions, Inc. Corporate website http://www.marineexhaustsolutions.com/
32 Krystallon, "Sea Water Scrubbing, Facts and Fantasy," Presentation at Clean Ships Conference, Sand Diego, CA,
  February 9, 2007.
33 Global Trade and Fuels Assessment "Future Trends and Effects of Requiring Clean Fuels in the Marine Sector,"
  Prepared for EPA by RTI International, EPA420-R-08-021, November 2008, available at:
  http://www.epa.qov/oms/reqs/nonroad/marine/ci/420r08021.pdf. This report, in turn, is based largely on the Fuel
  Switching presentations to the California ARB, 7/27/08, available at
  http://www.arb.ca.qov/ports/marinevess/presentations.htm. First order references are provided where appropriate.
34 Also referred to as residual oil (RO). Intermediate fuel oil (IFO) is used commonly.
35 Keith Michel, Herbert Engineering Corp., "California Maritime Technical California Maritime Technical Working
  Group Focus on Fuel Switching: Fuel Oil Systems," July 24, 2007, available at
  http://www.arb.ca.qov/ports/marinevess/presentations/072407/072407herpres.pdf.
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improve  operational efficiency, and  maintain  the  fuel circulation, injection,  and combustion
systems. These systems consist of storage and settling tanks, filters, and purifiers.

Fuel is transported from  heated bunker tanks to the settling tank by transfer pumps. Settling
tanks hold enough fuel for approximately 2 days of travel and have coils to heat the fuel, if
heating is not maintained, the fuel will become too viscous to pump. In the settling tanks, heavy
fuel solids settle to the bottom while fuel to be burned is drawn from the top of the tank.  Fuel is
then pumped  from the settling tank through a  pre-heater and  into one  or  more centrifugal
separators by  feed pumps. This fuel is then pumped to the day tank, where approximately one
day's reserve  of pre-treated and  cleaned fuel  is maintained at an appropriate temperature to
maintain  fuel viscosity for use in the engine. The  engine fuel  supply system then draws fuel
beyond that necessary for combustion from the day tank to the injection system and circulates
the additional  fuel  back to the day tank to prevent solidification throughout the supply system.
Sets of supply and circulating pumps pressurize the system and transfer fuel from the day  tank,
the final  engine fuel filter, and injectors while a pre-heater and  viscosity  meter maintain fuel
viscosity  throughout the  fuel system.  Figure 2-12 shows a typical  shipboard fuel  delivery
system. Figure 2-13 shows a fuel system as a layout onboard the vessel.

                   Figure 2-13. Typical Shipboard Unifuel Delivery System
                      Source: RTI International
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                      Figure 2-14. Typical Fuel Tank and Delivery Systems

                Containership                                     Tanker

                 t
          HFO Service
       HFO Storage
Bunter Station Tarks
(PIS)


  36
Source: Herbert Engineering Corp

2.3.2.    Potential vessel modifications associated with fuel s witching
Technical concerns regarding use of low-sulfur distillate fuels in Category 3 vessel engines
relate to either steady-state operation on distillate fuels or the process of switching fuels.

Steady-state distillate fuel use may  raise issues of cylinder lubricants and feed rates and fuel
viscosity and temperature control. Low-speed, 2-stroke engines inject lubricating oil  into the fuel
prior to combustion, potentially requiring separate fuel-feed systems to implement fuel switching
so that the proper  oil is used with the fuel  in use. Cylinder lubricating oils  contain alkaline
additives to counteract the  acidity caused by sulfur oxides and must be mated appropriately to
the sulfur content of the fuel used to control the deposition of acids in the cylinders and reduce
wear. Wartsila recommends use of 70 base number (BN) cylinder oil when using fuels with 1.5
percent or more sulfur and 40BN oil for fuels with lower sulfur levels.37 During periods  of fuel
switching, the BN to sulfur ratio (BN/S) can  be out of balance. While unbalanced  BN/S ratios
cause excess engine wear, it is believed that changing lube oil is  only necessary if  the engines
are to operate on fuel that is 1 percent sulfur or less for more  than one week.38 For  longer
periods, ships may require two cylinder lubricating oil systems.  However, there is an oil that has
36 Herbert Engineering Corp., http://www.arb.ca.gov/ports/marinevess/presentations/072407/072407herpres.pdf
37 Wartsila Switzerland Ltd, LOW SULPHUR GUIDELINES: Guidelines for design, modification and operation of new
  buildings and existing ships to comply with future legislation related to low sulphur content in the fuel, Updated: 9th
  January, 2006. Available at:
  http://www.wartsila.eom/Wartsila/qlobal//docs/en/ship power/media  publications/technical papers/low sulphur qu
  idelines.pdf.
38 MAN B&W, Operation on Low-Sulphur Fuels Two-Stroke Engines, available at:
  http://www.manbw.com/article 005271.html.
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been  recently developed  for use with distillate or residual,  so this might  not  be the case
anymore.

In addition to BN/S matching, long term use of distillate fuels must consider viscosity matches
between the fuel and the injection system design, as MDO  and MGO are significantly  less
viscous than HFO. Although use  of low viscosity fuels in medium speed, 4-stroke engines is
generally not a concern, severe cases may lead to damaged fuel injection equipment and power
loss. For low-speed, 2-stroke engines viscosity effects are typically minor, but may be affiliated
with failed fuel treatment system pumps. Both cases may be mitigated by installation and use of
a  fuel  cooler, associated piping,  and  viscosity meters to the fuel treatment system  if fuel
switching is done on a frequent basis.

Although  all  the above mentioned concerns  are legitimate,  it should be  noted  that in its
presentation  to ARE,  Maersk39 illustrated that  all  its  vessels switch both  main  and auxiliary
engines to MDO with less than 0.2 percent sulfur within 24 nautical miles of their California
destination port  for main  engines and within  24  nautical miles  of the California border for
auxiliary engines. They have noted no problems to date on their vessels from this program.

The Maersk study included 78 vessels and 298 switches consuming 23.9 MT of MDO per switch
from April 2006 to April  or  May 2007.  The  resulting total  emissions reduction has  been
calculated at 800 tons per year, including a 95 percent SOx,  87 percent PM, and  12 percent
NOx reduction (which  includes low-NOx  auxiliary  mode).  These  reductions  are  greater than
anticipated by the  program. In the Maersk study, all vessels  used separate  service tanks for
high-  and low-sulfur fuels (DMA  and  DMB, with  DMX for lifeboat engines  and emergency
generator use) to minimize compatibility  issues. Also, as all fuel  switching in this program is
considered short term,  they made  no cylinder lube oil BN  change. Maersk noted  that fuel
switching is considered "normal engineering practice" and provides no special training.

Some ships may not have sufficient onboard storage capacity to accommodate temporary fuel
switching  since the minimum space practical is devoted to fuel and machinery  to maximize
cargo and, of the space devoted to fuel, a minimal  amount is provided for distillate oil tanks on
unifuel ships. Some dual fuel ships have two fuel oil tank systems—one for residual and one for
lower sulfur distillate oil. This  arrangement may be preferred for fuel switching, since it avoids
many issues with using  dissimilar  fuels in the same fuel system while still meeting lower sulfur
requirements. The common arrangement  is for one HFO tank system with multiple HFO tanks
and associated fuel system and another  distillate oil system with one or more MDO or MGO
storage tanks and a corresponding day tank.

At their presentation to ARE, Herbert Engineering36 surveyed a range of vessels and their ability
to switch fuels. They found that,  for tanker ships varying from  a  50,000 DWT Panamax  to a
300,000 DWT VLCC (Very Large Crude Carrier)  vessels, while  the HFO capacity and number of
tanks and ancillary system components varied, the total capacity for distillate fuels remained at
one settling and  one service tank of varying volume with sufficient capacity for between 3.3 and
3.6 days operating range using distillate fuels in both main and auxiliary engines and  in  at-sea
cruising mode with a 15 percent reserve. Typical containerships profiled ranged  from a 2,500
TEU Feedership to a 9,000 TEU Post-Panamax containership. All cases have one storage tank
and one service  tank for distillate fuels except the largest containership,  which had two storage
tanks and one distillate service tank. Again, while total distillate storage volumes varied, the at-
39 Maersk Pilot Fuel Switch Initiative, A.P. Moller-Maersk Group, Regulatory Affairs Technical Organisation, 26 July
  2007, available at http://vwvw.arb.ca.qov/ports/marinevess/presentations/072407/072407maepres.pdf.
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sea cruising range using distillate fuels in both the main and auxiliary systems varied from 1.7 to
2.6 days. This study concluded that existing distillate oil tank capacities should be sufficient to
accommodate main and auxiliary engine operation in SECAs. Typical onboard storage volumes
and number of tanks by fuel type are shown in Table 2-7.

     Table 2-7. Typical on-board storage for heavy fuel oil and distillate fuels by vessel type
Ship Type/Size
Tank
Description
Volume
(m3)
Tank
Description
Volume
(m3)
 Container Vessels
2500 TEU Feedership
4000 TEU Panamax Containership
6000 TEU Post-Panamax Containership
9000 TEU Post-Panamax Containership
6 HFO Storage
+ 1 Settling
+ 1 Storage
8 HFO Storage
+ 1 Settling
+ 1 Storage
10 HFO Storage
+2 Settling
+ 1 Storage
12 HFO Storage
+2 Settling
+2 Storage
3,200
7,000
8,000
10,000
1 DO Storage
+ 1 Service
1 DO Storage
+ 1 Service
1 DO Storage
+ 1 Service
2 DO Storage
+ 1 Service
300
350
400
800
 Tanker Vessels
50,000 DWT Panamax Tanker
1 10,000 DWT Aframax Tanker
160,000 DWT Suezmax Tanker
300,000 DWT VLCC
2 HFO Storage
+ 1 Settling
+ 1 Storage
4 HFO Storage
+ 1 Settling
+ 1 Storage
4 HFO Storage
+ 1 Settling
+ 1 Storage
4 HFO Storage
+2 Settling
+ 1 Storage
1,500
3,000
4,000
5,500
1 DO Storage
+ 1 Service
1 DO Storage
+ 1 Service
1 DO Storage
+ 1 Service
1 DO Storage
+ 1 Service
150
250
350
450
Source: Herbert Engineering Corp.
                          36
Fuel use for a typical call for an average container ship and an average tanker are shown in
Table 2-8 as a function of EGA distance from shore.  Assuming the typical container ship is a
4000 TEU Panamax and the typical tanker is a 110,000 DWT Aframax, current fuel storage of
distillate fuel is 343 metric tonnes and 245 metric tonnes respectively based upon a MGO fuel
density of 980 kg/m3.  Thus even if the EGA is set at 200 nautical miles, a typical ship can make
three to four calls into and out of a port before needing to refuel with existing distillate tanks.  It
should be noted  that the fuel amounts in Table 2-8 represent average vessels, therefore, some
vessels may require additional capacity to accomplish fuel switching.

            Table 2-8. Fuel Use per Call  for Various EGA Distances (Metric Tonnes)
EGA
Distance
25
50
100
200
Container
25.10
35.31
55.74
96.59
Tanker
19.98
25.46
36.44
58.40
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If a new or segregated tank is desired, ancillary equipment such as pumps, piping, vents, filing
pipes,  gauges, and access  would be  required, as well  as  tank testing.40   In addition, fuel
processing systems include settling tanks, filters, and centrifuges may also be necessary. While
some vessel operators may  be  able to use their existing processing systems, other operators
have reported that they will need to add to these systems,  along with increased fuel capacity or
other modifications.41

Also, should full-time switching  from  the  use of high- to low-sulfur fuels be implemented,  the
Herbert Engineering study concluded that existing engines and fuel oil systems are suitable for
continuous operation on distillate fuels, although will require use of lubricating oil with a different
BN.

2.3.3.   Modifications for fuel s witching
In its March 2008 presentation,42 ARE documented results from its 2006 vessel survey. ARB's
results showed that approximately 22 percent of vessels surveyed needed some modifications
to adequately perform main  engine fuel switching, but the modifications  needed  and  vessels
requiring the modifications varied both with distance and vessel type. For main engine fuel
switching, the required modifications included:
       o  Fuel tanks
          Cylinder lube oil systems
          Fuel valves
          Fuel piping and pumps
       o  Engine fuel pumps
       o  Fuel injectors

The ARE survey also found that 94 percent of vessels could participate in an auxiliary engine-
only fuel switching  program without any modifications. Of those that did require modifications,
the required retrofits included the following:
       o  Fuel oil system
       o  Fuel tanks and lines
       o  Fuel injection/oil pump modifications
       o  Fuel oil micronizer
       o  Storage  tanks
       o  Diesel fuel cooler
       o  Change  lube oil BN and add cooling lines for fuel oil pumps
o

o

o
40 Entec UK Limited. Quantification of Emissions from Ships Associated with Ship Movements between Ports in the
  European Community, July 2002, pps. 86-87.
41 Air Resources Board, "Fuel Sulfur And Other Operational Requirements For Ocean-Going Vessels Within
  California Waters And 24 Nautical Miles Of The California Baseline - Initial Statement of Reasoning," June 2008.
422006 Ocean-Going Vessel Survey Results, Cal EPA Air Resources Board, 4th Public Workshop to Discuss
  Development of Regulations for Ocean-going Ship Main Engines and Auxiliary Boilers, March 5, 2008,
  Sacramento, CA.
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A small number of survey participants reported the need to modify engine components such as
fuel pumps, injectors, and  nozzles. However, engine manufacturers have  stated that, with
certain caveats, the engines they designed for heavy fuel  oil can also operate on MGO without
these modifications.41  In most cases, the need for fuel injection pumps and nozzles arises from
the fact that older ship engines used nitrile rubber seals  and o-rings which are susceptible to
shrinking when a  hydrogenated lower sulfur distillate fuel  is used  after running for long periods
on heavy fuel  oils.  This causes leaks in both the fuel injector  pumps and  nozzles.  Newer
pumps and injectors use Viton® o-rings, which are much  less susceptible to fuel  changes.  In
some cases, replacement of old o-rings and seals will be necessary  as an early  maintenance
item to prevent problems.

2.3.4.  Scenarios analyzed and cost methodology

Three fuel switching cases are analyzed here for costs in Section 3, namely:

       •   Case 0: Vessels meet all requirements of a EGA and require no  modifications or
          retrofits (baseline).

       •   Case   1: A newly built  vessel  requires  additional equipment to  meet  EGA
          requirements over comparable new vessels.

       •   Case 2: Existing vessels will require retrofits to meet EGA requirements.

In all cases here,  we have assumed that both  propulsion  and auxiliary engines will operate on
the same distillate fuel when near the coastline for a continuous period of less than 1 week and
that the  distillate  fuel will be  0.1 percent sulfur  MGO.   This analysis does not attempt to
determine the number of ships that would require these modifications.

As discussed above, for short periods of operation on lower sulfur fuel for low speed,  2-stroke
engines,  a switch  to lower cylinder lube oil TEN is  not necessary. We have assumed that within
the one week period considered here is within that range.  Note that this switch  is not applicable
to 4-stroke engines.

We have based  all calculations on the estimate that any retrofit distillate  tanks would  be
designed  to hold  250 hours of fuel under normal  operation. This is larger  than is currently
available on most ships that currently carry distillate fuel as noted in the Herbert Engineering
presentation (see Table 2-7).  In building these tanks, we have assumed that they will  be
composed of cold  rolled steel 1  mm thick and double walled.

Because  fuel treatment systems vary by vessel and the fuel switching program will vary with the
vessel treatment  system, characterizing  general costs is  difficult. However,  most ships  have
distillate systems  onboard, although fuel  switching may require modifications  to accommodate
the distillate usage envisioned here. The system envisioned here  is most like MAN B&Ws Fuel
Oil System No.  1  with  one distillate  and one heavy fuel oil settling tank, shown by Figure 2-14.
Here, both HFO and MDO have a dedicated bunkering, settling, centrifuging,  and service tank
system. The distillate and  residual systems are independent until fuel supply pressurization, and
the injection systems are shared.  If MGO is used instead, the settling tank and centrifuge might
not be necessary.
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                           Figure 2-15. MAN B&W's Fuel Oil System No. 1
                        ©	
          MDO Storage Tank (25°C)
                                           MGO
                                      !  (Boiler Support)   J-—
                                      |  (Inert Gasjeto}
                                         Centrifuge(s)
                                           (40°C)
 Bunker Storage Tank 1 (45°C)
    Bunker Storage Tank 2 (45°C)
        Bunker Storage Tank 3 (45°C)
                                                                 HFO Supply  HFO Circulating
                                                                   pump        pump
Centrifuge(s)
(95-100°C)
   Source: MAN B&W38
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3.    Economic Impact
3.1.  Cost Estimation Methodology
In order to determine the  estimated  cost  of  compliance with potential  future  emission
regulations, representative models of low- and medium-speed Category 3 marine diesel engines
were chosen among several  manufacturers' engine lines and costs were estimated  for each.
No single model's costs were  used to develop the estimates presented in this report. Once cost
information was developed, cost spreadsheets were shared  with engine and emission  control
equipment manufacturers for  comment.  Presented costs for  each technology represent a best
estimate based upon all the input received.

Costs for the technologies discussed in  Section 2 are presented in this section. These costs
include  hardware costs and  fixed costs.   Costs  for changes  in fuel consumption  are also
discussed.  All costs represent the incremental costs for engines to meet the proposed emission
standards.

Typically, Category 3 engines and emission reduction technologies are built outside the United
States.  All costs  have been converted to 2006 U.S. dollars.

3.1.1.  Hardware Cost to Manufacturer

Component costs were developed for each technology discussed in Section 2. Separate costs
were derived  for each of the  various engines shown in Table 2-2. Manufacturer costs of
components were estimated  from  various  sources including information from marine diesel
engine manufacturers,  and previous work performed by the  author of this document.43   Labor
rates used in this study were  taken from  Salary.com44 for New Jersey and include a 60 percent
fringe rate as shown in  Table 3-1.

                                 Table 3-1. Labor Rates
Labor Category
Annual
Salary
60% Fringe
Annual
Rate
Hourly
Rate
Design Engineer II $75,000 $45,000 $120,000 $57.69
Mechanic Technician II $50,000 $30,000 $80,000 $38.46
Floor Assembler II $31,000 $18,600 $49,600 $23.85
Hardware costs provided by a supplier other than the engine manufacturer are subject to a 29
percent mark up, which represents an average supplier mark up of technologies on new engine
sales.45

3.1.2.  Fixed Cost to Manufacturer
The fixed costs to the manufacturer consist of the cost of researching, developing and testing a
new  technology.  They also include the cost of retooling for the production of  new  parts.
Research and development  costs reflect the need for manufacturers to focus on adapting
43 L.Browning and R. Barnitt, "Emission Reduction Technology Costs for Category 3 Marine Diesel Engines," April
  2002
44 http://www.salarv.com
45 Jack Faucett Associates, "Update of EPA's Motor Vehicle Emission Control Equipment Retail Price Equivalent
  (RPE) Calculation Formula," Report No. JACKFAU-85-322-3, September 1985.
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          Costs of Emission Reduction Technologies for Category 3 Marine Engines
                                   Economic Impact


emission  controls to specific  marine  diesel engine  applications,  with  significant  engine
calibration needed to optimize these controls over a large range of ship types and operating
conditions.

Each year of research and development has been defined as 1 engineer and 2 technicians plus
24 engine tests per year at $10,000 per test. Total R&D costs per year are shown in Table 4-1.

                    Table 3-2. Annual Research and Development Costs
                          1 engineer
                          2 technician
                          40% overhead
                          24 Tests @ $10,000 per test
           $120,000
           $160,000
           $168,000
           $240,000
           $688,000
In addition, a $5,000 fee is added for Marine Society approval of the technology. All real costs
calculated in this report are in 2006 dollars with future costs discounted at 7 percent per annum.
R&D costs are expected to occur over a three year period ending one year prior to engine
production. Tooling costs are expected to occur one year prior to engine production. Both R&D
and tooling costs are expected to be  recovered over the first five years of engine sales. Cost of
money was assumed to be 7 percent per annum for these calculations. The estimated number
of units per year was supplied by EPA.

3.1.3.  Fuel Economy

As discussed in Section 2, many of the technologies can lead to either a fuel cost savings or
cost penalty for the user.  An estimate of these changes in fuel consumption is developed in this
report by using  engine characteristics such as brake specific fuel consumption (BSFC) and load
factors.

The BSFC used in the analysis is listed in Table 2-2.  For an  average call, assuming that the
Emission Control  Area (EGA) starts 200 nautical miles (nm) from U.S. shores,  average load
factors for propulsion and auxiliary engines  are given in Table 3-3.

                             Table 3-3. Average Load Factors
Mode
Cruise
Transit
Maneuver
Hotel
Total/Average
Speed
(knots)
17.4
12
5
-

One-Way
Distance
(nm)
200
12
5
-

Time per
Call
(Hours)
23.0
2.0
2.0
55.5
82.4
Propulsion
Load Factor
83%
27%
2%

73%
Auxiliary
Load
Factor
19%
30%
51%
35%
31%
Using the following formula, an estimate of the yearly fuel consumption for a 1% change in fuel
consumption  is determined.  Actual fuel use can be scaled from this value using the ratio of
actual fuel consumption change to the 1% change calculated here.

 Annual Fuel Use = (Avg BSFC) * (Nominal hp) * (Load Factor) * (Annual hr of operation)
ICF International
EPA Contract EP-C-06-094, WA 2-08
3-2
U.S. Environmental Protection Agency
                    April 20099

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Medium
18,000
16
95
500
Low
8,500
6
380
130
Low
15,000
8
650
110
Low
48,000
12
1400
100
          Costs of Emission Reduction Technologies for Category 3 Marine Engines
                                   Economic Impact


3.2.  Retrofit Tier I  Technology  Costs
The costs for the retrofit kit include new fuel injectors plus 3 months R&D to modify timing. A
Marine Society approval certificate is also included.  As part of the IMO regulations, the retrofit
kit cannot exceed $375 Special Drawing Rights  (SDR)/metric tonne of NOx reduced.  The
currency value of the SDR is determined by summing the values in U.S. dollars, based on
market exchange rates, of a basket of major currencies (the U.S. dollar, Euro, Japanese yen,
and pound sterling). The SDR currency value is  calculated daily and the valuation basket is
reviewed and adjusted every five years.  Current conversion rates  are $1.49129 per SDR. As
can be seen from Table 3-4, the cost effectiveness of the retrofit kits described above are
significantly less than the maximum cost allowed in Annex VI.
                               Table 3-4. Cost of Retrofit Kits
 Speed
 Engine Power (kW)
 Cylinders
 Liters/cylinder
 Engine Speed (rpm)
 Hardware Cost to Engine Manufacturer
 Component Costs
   Number of Injectors
   Improved Fuel Valves (each)
 Total Component Cost
 Assembly
   Labor (hours)
   Cost($23.85/hr)
   Overhead  @ 40%
 Total Assembly Cost

 Total Variable Cost
 Markup @ 29%
 Total Hardware RPE

 Fixed Costs
 R&D Costs (0.25 year R&D)
 Marine Society Approval
 Engines/yr.
 Years to recover
 Fixed cost/engine

 Total Costs
 Cost/kW

 Estimated Emission Reduction (MT NOx)
 Cost Effectiveness (SDR/MT NOx)
     16
   $235
  $3,760
     18
   $235
  $4,230
     24
   $375
  $9,000
$172,000
  $5,000
     40
      5
  $1,233

 $11,251
    $0.6

  638.67
   $11.8
$172,000
  $5,000
     40
      5
  $1,233

 $13,925
    $1.6

  389.92
   $23.8
$172,000
  $5,000
     40
      5
  $1,233

 $22,145
    $1.5

  688.09
   $21.5
     36
   $470
 $16,920
120
$2,862
$1,145
$4,006
$7,766
$2,252
$10,018
168
$4,006
$1,602
$5,609
$9,839
$2,853
$12,692
216
$5,151
$2,060
$7,211
$16,211
$4,701
$20,912
312
$7,440
$2,976
$10,416
$27,336
$7,927
$35,263
$172,000
  $5,000
     40
      5
  $1,233

 $36,496
    $0.8

 2,201.89
   $11.1
For estimated emission reduction, emission reductions are calculated at 11 percent of baseline
emissions for 6000 hours per year for 5 years with a load factor of 0.768. Baseline NOx
emission rates are 14 g/kWh for medium speed engines and 18.1 g/kWh for slow speed
engines. Emission reductions in metric tonnes are thus calculated as follows:
ICF International
EPA Contract EP-C-06-094, WA 2-08
   3-3
         U.S. Environmental Protection Agency
                             April 20099

-------
          Costs of Emission Reduction Technologies for Category 3 Marine Engines
                                    Economic Impact

Slow Speed Engines:  18.1 g/kWh x Power (kW) x 0.768 x 6000 hours/yrx5 years/1000000 g/metric tonne x 11%

Medium Speed engines: 14 g/kWh x Power (kW)x 0.768 x 6000 hours/yrx 5 years/1000000 g/metric tonne x 11%

3.3.  Tier II Technology  Costs

As  discussed in Section  2, Tier II  technology costs include engine modification  costs  and
common rail fuel injection system costs.  Engine modification costs to meet proposed Tier II
emission levels are given in Table 3-5.  These costs  include modification of fuel injection timing,
increasing the compression ratio, fuel injection nozzle  optimization  and  Miller cycle effects.
Retooling  costs include  cylinder  head and  piston   rod  shim modifications  to  increase
compression ratios as well as to accommodate different injection nozzles.

       Table 3-5. Differential Costs for Engine Modifications to Meet Tier II Emission Levels
 Engine Speed              Medium     Medium    Medium      Low         Low        Low
 Engine Power (kW)           4,500      9,500       18,000       8,500       15,000       48,000
 Cylinders                    9         12          16          6          8          12
 Liters/cylinder               35         65          95         380         650        1400
 Engine Speed (rpm)           650        550         500        130         110         100

 Fixed Costs
 R&D Costs (1 year R&D)      $688,000    $688,000     $688,000    $688,000     $688,000     $688,000
 Retooling Costs             $500,000    $750,000    $1,000,000    $750,000   $1,000,000   $1,250,000
 Marine Society Approval        $5,000     $5,000       $5,000      $5,000      $5,000      $5,000
 Engines/yr.                      40        40           40         40          40          40
 Years to recover                   55           55           5           5
 Fixed cost/engine            $8,103     $9,734      $11,365      $9,734      $11,365      $12,996

 Total Costs                  $8,103     $9,734      $11,365      $9,734      $11,365      $12,996
 Cost per kW                   $1.8       $1.0         $0.6        $1.1         $0.8         $0.3

Differential costs for new common rail fuel  injection engines that replace engines that were
mechanically injected  are  given  in Table 3-6.  Differential costs for common  rail fuel injection
engines that replace engine that were previously electronically controlled are given in Table 3-7.
Retooling costs include modification of the cylinder head to accommodate  common rail  fuel
injection systems.
ICF International                               3-4               U.S. Environmental Protection Agency
EPA Contract EP-C-06-094, WA 2-08                                                        April 20099

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           Costs of Emission Reduction Technologies for Category 3 Marine Engines
                                     Economic Impact
Table 3-6. Common Rail Fuel Injection Costs for Mechanically
Speed
Engine Power (kW)
Cylinders
Liters/cylinder
Engine Speed (rpm)
Hardware Cost to Engine Manufacturer
Component Costs
Electronic Control Unit
Common Rail Accumulators (each)
Number of Accumulators
Low Pressure Pump
High Pressure Pump
Modified injectors (each)
Number of injectors 9
Wiring Harness
Total Component Cost
Assembly
Labor (hours)
Cost($23.85/hr)
Overhead @ 40%
Total Assembly Cost
Total Variable Cost
Markup @ 29%
Total Hardware RPE
Fixed Costs
R&D Costs (1 year R&D)
Retooling Costs
Marine Society Approval
Engines/yr.
Years to recover
Fixed cost/engine
Total Costs
Cost per kW
Medium
4,500
9
35
650


$3,500
$2,000
3
$2,000
$3,500
$2,500

$2,500
$40,000

120
$2,862
$1,145
$4,006
$44,006
$12,762
$56,768

$688,000
$1,000,000
$5,000
40
5
$11,365
$68,133
$15.1
Medium
9,500
12
65
550


$3,500
$2,000
6
$3,000
$4,500
$2,500
12
$2,500
$55,500

160
$3,815
$1,526
$5,342
$60,842
$17,644
$78,486

$688,000
$1,000,000
$5,000
40
5
$11,365
$89,850
$9.5
Medium
18,000
16
95
500


$3,500
$2,000
8
$4,000
$6,000
$2,500
16
$2,500
$72,000

200
$4,769
$1,908
$6,677
$78,677
$22,816
$101,493

$688,000
$1,000,000
$5,000
40
5
$11,365
$112,858
$6.3
Injected Engines
Low
8,500
6
380
130


$5,000
$2,000
9
$2,500
$4,500
$3,500
18
$3,000
$96,000

200
$4,769
$1,908
$6,677
$102,677
$29,776
$132,453

$688,000
$1,000,000
$5,000
40
5
$11,365
$143,818
$16.9
Low
15,000
8
650
110


$5,000
$2,000
12
$3,500
$6,000
$3,500
24
$3,000
$125,500

250
$5,962
$2,385
$8,346
$133,846
$38,815
$172,662

$688,000
$1,000,000
$5,000
40
5
$11,365
$184,026
$12.3
Low
48,000
12
1400
100


$5,000
$2,000
18
$4,500
$8,000
$3,500
36
$3,000
$182,500

300
$7,154
$2,862
$10,015
$192,515
$55,829
$248,345

$688,000
$1,000,000
$5,000
40
5
$11,365
$259,710
$5.4
ICF International
EPA Contract EP-C-06-094, WA 2-08
3-5
U.S. Environmental Protection Agency
                     April 20099

-------
ledium
4,500
9
35
650
Medium
9,500
12
65
550
Medium
18,000
16
95
500
Low
8,500
6
380
130
Low
15,000
8
650
110
Low
48,000
12
1400
100
$500
$2,000
3
$1,000
$1,500
$500
9
$500
$14,000
$500
$2,000
6
$1,000
$1,500
$500
12
$500
$21,500
$500
$2,000
8
$1,000
$1,500
$500
16
$500
$27,500
$500
$2,000
9
$1,500
$2,000
$750
18
$650
$36,150
$500
$2,000
12
$1,500
$2,000
$750
24
$650
$46,650
$500
$2,000
18
$1,500
$2,000
$750
36
$650
$67,650
          Costs of Emission Reduction Technologies for Category 3 Marine Engines
                                    Economic Impact


              Table 3-7. Common Rail Fuel Injection Costs for Electronic Engines
 Speed
 Engine Power (kW)
 Cylinders
 Liters/cylinder
 Engine Speed (rpm)

 Hardware Costs to the Manufacturer
 Component Costs
   Electronic Control Unit
   Common Rail Accumulators (each)
   Number of Accumulators
   Low Pressure Pump
   High Pressure Pump
   Modified injectors (each)
   Number of injectors
   Wiring Harness
 Total Component Cost
 Assembly
   Labor (hours)
   Cost ($23.85/hr)
   Overhead @40%
 Total Assembly Cost

 Total Variable Cost
 Markup @ 29%
 Total Hardware RPE

 Fixed Costs
 R&D Costs (0.5year R&D)
 Retooling Costs
 Marine Society Approval
 Engines/yr.
 Years to recover
 Fixed cost/engine

 Total Costs
 Cost per kW

3.4.  Tier III Technology Costs

As discussed in Section 2,  several options have been discussed  to  meet proposed Tier III
emission levels. These include engine modifications, fumigation, fuel  emulsions, direct water
injection, exhaust gas recirculation, selective catalytic reduction and seawater scrubbing.  Fuel
switching costs are discussed in Section 3.4.

3.4.1.  Engine Modifications
Engine modifications to meet proposed Tier III emission  levels include use  of  two stage
turbochargers and electronic valve actuation.  Table 3-8 shows incremental costs  for engine
40
$954
$382
$1,335
$15,335
$4,447
$19,783
60
$1,431
$572
$2,003
$23,503
$6,816
$30,319
80
$1,908
$763
$2,671
$30,171
$8,750
$38,920
40
$954
$382
$1,335
$37,485
$10,871
$48,356
60
$1,431
$572
$2,003
$48,653
$14,109
$62,762
80
$1,908
$763
$2,671
$70,321
$20,393
$90,714
$344,000
$500,000
$5,000
40
5
$5,698
$26,700
$5.9
$344,000
$500,000
$5,000
40
5
$5,698
$34,868
$3.7
$344,000
$500,000
$5,000
40
5
$5,698
$41,535
$2.3
$344,000
$500,000
$5,000
40
5
$5,698
$48,850
$5.7
$344,000
$500,000
$5,000
40
5
$5,698
$60,018
$4.0
$344,000
$500,000
$5,000
40
5
$5,698
$81,685
$1.7
ICF International
EPA Contract EP-C-06-094, WA 2-08
3-6
U.S. Environmental Protection Agency
                    April 20099

-------
          Costs of Emission Reduction Technologies for Category 3 Marine Engines
                                    Economic Impact
modifications  to meet the  proposed Tier III emission levels.
turbocharger redesign and valve actuation modifications.
                                Retooling  costs represent
dium
4,500
9
35
650
Medium
9,500
12
65
550
Medium
18,000
16
95
500
Low
8,500
6
380
130
Low
15,000
8
650
110
Low
48,000
12
1400
100
$16,250
$285
2
$285
2
$3,750
$2,800
$33,060
$9,587
$42,647
$20,900
$285
2
$285
2
$3,750
$2,800
$41,130
$11,928
$53,058
$46,750
$285
2
$285
2
$3,750
$2,800
$71,540
$20,747
$92,287
$28,000


$425
4
$3,750
$2,800
$44,750
$12,978
$57,728
$42,000


$425
4
$3,750
$2,800
$62,150
$18,024
$80,174
$61,000


$425
4
$3,750
$2,800
$87,950
$25,506
$113,456
        Table 3-8. Differential Engine Modifications Costs to Meet Tier III Emission Levels
 Speed                        Mi
 Engine Power (kW)
 Cylinders
 Liters/cylinder
 Engine Speed (rpm)

 Hardware Costs to the Manufacturer
 Component Costs
   2 Stage Turbochargers
   (Incremental)
   Electronic Intake Valves (each)
   Intake Valves per Cylinder
   Electronic Exhaust Valves (each)
   Exhaust Valves per Cylinder
   Controller
   Wiring
 Total Component Cost
 Markup @ 29%
 Total Hardware RPE

 Fixed Costs
 R&D Costs (1 year R&D)
 Retooling Costs
 Marine Society Approval
 Engines/yr.
 Years to recover
 Fixed cost/engine

 Total Costs
 Cost per kW

3.4.2.  Fumigation

Fumigation costs include costs for the water storage tank, the humidifier, the heat exchanger
and various pumps and piping and are shown in Table 3-9. Water tank cost details are shown
in Table 3-10 and estimate storage of water for 250 hours of normal operation when operating in
the emission control area (EGA). It is envisioned that the water tank is constructed of cold rolled
steel 1 mm thick.  Cold rolled steel prices are estimated at $686 per metric tonne and represent
average steel prices in 2006.46  Water usage costs are shown  in Table 3-11 and are estimated
assuming a cost of $0.25/gallon for distilled water. For systems that use seawater, these costs
should not be considered.  Retooling costs are for redesign of the air intake system.
$688,000
$700,000
$5,000
40
5
$9,407
$688,000
$1,000,000
$5,000
40
5
$11,365
$688,000
$1,300,000
$5,000
40
5
$13,322
$688,000
$1,000,000
$5,000
40
5
$11,365
$688,000
$1,300,000
$5,000
40
5
$13,322
$688,000
$1,650,000
$5,000
40
5
$15,605
$52,055
  $11.6
$64,422
   $6.8
$105,608
    $5.9
$69,092
   $8.1
$93,495
   $6.2
$129,061
    $2.7
  MEPS Steel Prices On-line at http://www.steelonthenet.com/prices.html.
ICF International
EPA Contract EP-C-06-094, WA 2-08
           3-7
                 U.S. Environmental Protection Agency
                                     April 20099

-------
           Costs of Emission Reduction Technologies for Category 3 Marine Engines
                                     Economic Impact
Table 3-9. Fumigation Costs
Speed
Engine Power (kW)
Cylinders
Liters/cylinder
Engine Speed (rpm)
Medium
4,500
9
35
650
Medium
9,500
12
65
550
Medium
18,000
16
95
500
Low
8,500
6
380
130
Low
15,000
8
650
110
Low
48,000
12
1400
100
Hardware Costs to the Manufacturer
Component Costs
Water Tank
Humidifier
Heat Exchanger
Pump/Piping
Total Component Cost
Assembly
Labor (hours)
Cost($23.85/hr)
Overhead @ 40%
Total Assembly Cost
Total Variable Cost
Markup @ 29%
Total Hardware RPE
Fixed Costs
R&D Costs (1 year R&D)
Retooling Costs
Marine Society Approval
Engines/yr.
Years to recover
Fixed cost/engine
Total Costs
Cost per kW

$2,036
$70,000
$37,500
$5,600
$109,536

400
$9,538
$3,815
$13,354
$122,890
$35,638
$158,528

$688,000
$1,000,000
$5,000
40
5
$11,365
$169,892
$37.8

$3,253
$120,000
$47,000
$7,500
$170,253

600
$14,308
$5,723
$20,031
$190,284
$55,182
$245,466

$688,000
$1,000,000
$5,000
40
5
$11,365
$256,831
$27.0

$4,885
$240,000
$56,000
$9,500
$300,885

800
$19,077
$7,631
$26,708
$327,592
$95,002
$422,594

$688,000
$1,000,000
$5,000
40
5
$11,365
$433,959
$24.1

$2,775
$190,000
$47,000
$7,500
$239,775

750
$17,885
$7,154
$25,038
$264,813
$76,796
$341,609

$688,000
$1,000,000
$5,000
40
5
$11,365
$352,974
$41.5

$3,939
$310,000
$56,000
$9,500
$369,939

1000
$23,846
$9,538
$33,385
$403,323
$116,964
$520,287

$688,000
$1,000,000
$5,000
40
5
$11,365
$531,652
$35.4

$8,071
$700,000
$75,000
$11,300
$783,071

1250
$29,808
$11,923
$41,731
$824,802
$239,192
$1,063,994

$688,000
$1,000,000
$5,000
40
5
$11,365
$1,075,359
$22.4
ICF International
EPA Contract EP-C-06-094, WA 2-08
3-8
U.S. Environmental Protection Agency
                     April 20099

-------
          Costs of Emission Reduction Technologies for Category 3 Marine Engines
                                    Economic Impact
                          Table 3-10. Fumigation Water Tank Costs
 Speed
 Engine Power (kW)
 Cylinders
 Liters/cylinder
 Engine Speed (rpm)

 Water Tank Costs
   Fuel Amount (kg)
   Density (kg/mA3)
   Tank Size (mA3)
   Tank Material (mA3)
   Tank Material Cost ($)
 Assembly
   Labor (hours)
   Cost ($23.85/hr)
   Overhead @ 40%
 Total Assembly Cost
 Total Variable Cost
 Markup® 29%
 Total Hardware RPE
Medium
4,500
9
35
650
Medium
9,500
12
65
550
Medium
18,000
16
95
500
Low
8,500
6
380
130
Low
15,000
8
650
110
Low
48,000
12
1400
100
240,996
1,000
289
0.26
$1,411
508,769
1,000
611
0.43
$2,321
963,984
1,000
1,157
0.66
$3,553
422,699
1,000
423
0.34
$1,817
745,940
1,000
746
0.49
$2,653
2,387,008
1,000
2,387
1.07
$5,756
5
$119
$48
$167
$1,578
$458
$2,036
6
$143
$57
$200
$2,522
$731
$3,253
7
$167
$67
$234
$3,787
$1,098
$4,885
10
$238
$95
$334
$2,151
$624
$2,775
12
$286
$114
$401
$3,053
$885
$3,939
15
$358
$143
$501
$6,257
$1,814
$8,071
                         Table 3-11. Fumigation Distilled Water Costs
ledium
4,500
9
35
650
Medium
9,500
12
65
550
Medium
18,000
16
95
500
Low
8,500
6
380
130
Low
15,000
8
650
110
Low
48,000
12
1400
100
 Speed
 Engine Power (kW)
 Cylinders
 Liters/cylinder
 Engine Speed (rpm)

 Distilled Water Costs
   BSFC (g/kWh)
   Load factor
   Water/Fuel Ratio
   Water Use (kg/hr)
   Water Cost per kg
   Water cost per hour

3.4.3.  FuelEmulsification
Fuel emulsification costs include costs for the water storage tank, the ultrasonic homogenizer,
the heat exchanger, and various pumps and piping.  These are shown in Table 3-12.  Water
tank cost details are shown in Table 3-13 and estimate storage of water for 250 hours of normal
operation when operating in the emission control area (EGA).  It is envisioned  that the water
tank is constructed of cold rolled steel 1 mm thick. Water usage costs are shown in Table 3-14
and  are estimated assuming a cost of $0.25/gallon for distilled water.  Retooling costs are for
redesign of the  fuel system to accommodate fuel emulsification.
210
73%
1.40
964
$0.0264
$25
210
73%
1.40
2,035
$0.0264
$54
210
73%
1.40
3,856
$0.0264
$102
195
73%
1.40
1,691
$0.0264
$45
195
73%
1.40
2,984
$0.0264
$79
195
73%
1.40
9,548
$0.0264
$252
ICF International
EPA Contract EP-C-06-094, WA 2-08
3-9
U.S. Environmental Protection Agency
                    April 20099

-------
          Costs of Emission Reduction Technologies for Category 3 Marine Engines
                                     Economic Impact
Table 3-12. Fuel Emulsification Costs
Speed
Engine Power (kW)
Cylinders
Liters/cylinder
Engine Speed (rpm)
Medium
4,500
9
35
650
Medium
9,500
12
65
550
Medium
18,000
16
95
500
Low
8,500
6
380
130
Low
15,000
8
650
110
Low
48,000
12
1400
100
Hardware Costs to the Manufacturer
Component Costs
Water Tank
Ultrasonic Homogenizer
Heat Exchanger
Pump/Piping
Total Component Cost
Assembly
Labor (hours)
Cost($23.85/hr)
Overhead @ 40%
Total Assembly Cost
Total Variable Cost
Markup @ 29%
Total Hardware RPE
Fixed Costs
R&D Costs (1 year R&D)
Retooling Costs
Marine Society Approval
Engines/yr.
Years to recover
Fixed cost/engine
Total Costs
Cost per kW

$1,132
$37,500
$9,400
$4,700
$52,732

240
$5,723
$2,289
$8,012
$60,745
$17,616
$78,361

$688,000
$500,000
$5,000
40
5
$8,103
$86,463
$19.2

$1,767
$56,000
$11,700
$5,600
$75,067

320
$7,631
$3,052
$10,683
$85,750
$24,867
$110,617

$688,000
$500,000
$5,000
40
5
$8,103
$118,720
$12.5

$2,610
$75,000
$14,000
$6,600
$98,210

400
$9,538
$3,815
$13,354
$111,564
$32,354
$143,918

$688,000
$500,000
$5,000
40
5
$8,103
$152,020
$8.4

$1,611
$56,000
$11,700
$5,600
$74,911

320
$7,631
$3,052
$10,683
$85,595
$24,822
$110,417

$688,000
$500,000
$5,000
40
5
$8,103
$118,520
$13.9

$2,240
$75,000
$14,000
$6,600
$97,840

400
$9,538
$3,815
$13,354
$111,194
$32,246
$143,441

$688,000
$500,000
$5,000
40
5
$8,103
$151,543
$10.1

$4,386
$112,200
$16,400
$7,500
$140,486

480
$11,446
$4,578
$16,025
$156,511
$45,388
$201,899

$688,000
$500,000
$5,000
40
5
$8,103
$210,001
$4.4
ICF International
EPA Contract EP-C-06-094, WA 2-08
3-10
U.S. Environmental Protection Agency
                     April 20099

-------
          Costs of Emission Reduction Technologies for Category 3 Marine Engines
                                    Economic Impact
                         Table 3-13. Emulsification Water Tank Costs
 Speed
 Engine Power (kW)
 Cylinders
 Liters/cylinder
 Engine Speed (rpm)

 Water Tank Costs
   Fuel Amount (kg)
   Density (kg/mA3)
   Tank Size (mA3)
   Tank Material (mA3)
   Tank Material Cost ($)
 Assembly
   Labor (hours)
   Cost ($23.85/hr)
   Overhead @ 40%
 Total Assembly Cost
 Total Variable Cost
 Markup @ 29%
 Total Hardware RPE
 Speed
 Engine Power (kW)
 Cylinders
 Liters/cylinder
 Engine Speed (rpm)

 Distilled Water Costs
   BSFC (g/kWh)
   Load factor
   Water/Fuel Ratio
   Water Use (kg/hr)
   Water Cost per kg
   Water cost per hour
Medium
4,500
9
35
650
86,070
1,000
103
0.13
$711
5
$119
$48
$167
$878
$255
$1,132
Medium
9,500
12
65
550
181,703
1,000
218
0.22
$1,169
6
$143
$57
$200
$1,370
$397
$1,767
Table 3-14. Emulsification
Medium
4,500
9
35
650
210
73%
0.50
344
$0.0264
$9
Medium
9,500
12
65
550
210
73%
0.50
727
$0.0264
$19
Medium
18,000
16
95
500
344,280
1,000
413
0.33
$1,790
7
$167
$67
$234
$2,023
$587
$2,610
Distilled Water
Medium
18,000
16
95
500
210
73%
0.50
1,377
$0.0264
$36
Low
8,500
6
380
130
150,964
1,000
151
0.17
$915
10
$238
$95
$334
$1,249
$362
$1,611
Costs
Low
8,500
6
380
130
195
73%
0.50
604
$0.0264
$16
                              Low
                             15,000
                               8
                              650
                              110
                              266,407
                                1,000
                                 266
                                 0.25
                               $1,336

                                  12
                                $286
                                $114
                                $401
                               $1,737
                                $504
                               $2,240
                              Low
                             15,000
                               8
                              650
                              110
                                 195
                                 73%
                                 0.50
                                1,066
                              $0.0264
                                 $28
                       Low
                      48,000
                       12
                       1400
                       100
                      852,503
                        1,000
                          853
                         0.54
                       $2,899

                           15
                         $358
                         $143
                         $501
                       $3,400
                         $986
                       $4,386
                       Low
                      48,000
                       12
                       1400
                       100
                          195
                         73%
                         0.50
                        3,410
                      $0.0264
                          $90
3.4.4.  Direct Water Injection
Direct water injection costs include costs for the water storage tank,  a low pressure module, a
high pressure module, flow fuses, water injectors, related piping, and  the control unit and wiring
and  are shown in Table 3-15.  Water tank cost details are shown in Table 3-16 and estimate
storage of water for 250 hours of normal operation when operating in the EGA.  It is envisioned
that the water tank is constructed of cold rolled steel 1 mm  thick.  Water usage costs are shown
in Table 3-17 and are estimated assuming a cost of $0.25/gallon for distilled water. Retooling
costs are for redesign of the cylinder head to accommodate the direct  water injectors.
ICF International
EPA Contract EP-C-06-094, WA 2-08
3-11
U.S. Environmental Protection Agency
                     April 20099

-------
          Costs of Emission Reduction Technologies for Category 3 Marine Engines
                                     Economic Impact
Table 3-15. Direct Water Injection Costs
Speed
Engine Power (kW)
Cylinders
Liters/cylinder
Engine Speed (rpm)
Medium
4,500
9
35
650
Medium
9,500
12
65
550
Medium
18,000
16
95
500
Low
8,500
6
380
130
Low
15,000
8
650
110
Low
48,000
12
1400
100
Hardware Costs to the Manufacturer
Component Costs
Water Tank
Low Pressure Module
High Pressure Module
Flow Fuses (each)
Water Injectors (each)
Number per cylinder
Piping
Control Unit/Wiring
Total Component Cost
Assembly
Labor (hours)
Cost($23.85/hr)
Overhead @ 40%
Total Assembly Cost
Total Variable Cost
Markup @ 29%
Total Hardware RPE
Fixed Costs
R&D Costs (2 years R&D)
Retooling Costs
Marine Society Approval
Engines/yr.
Years to recover
Fixed cost/engine
Total Costs
Cost per kW

$1,132
$4,700
$9,500
$1,900
$2,400
1
$5,600
$9,500
$69,132

500
$11,923
$4,769
$16,692
$85,825
$24,889
$110,714

$1,376,000
$10,000,000
$5,000
40
5
$74,891
$185,605
$41.2

$1,767
$7,000
$14,000
$1,900
$2,400
2
$7,500
$11,300
$144,767

750
$17,885
$7,154
$25,038
$169,805
$49,244
$219,049

$1,376,000
$10,000,000
$5,000
40
5
$74,891
$293,940
$30.9

$2,610
$9,500
$19,000
$1,900
$2,400
3
$9,500
$13,000
$260,010

1000
$23,846
$9,538
$33,385
$293,395
$85,084
$378,479

$1,376,000
$10,000,000
$5,000
40
5
$74,891
$453,371
$25.2

$1,611
$9,500
$19,000
$1,900
$2,400
3
$9,500
$11,300
$128,311

1000
$23,846
$9,538
$33,385
$161,696
$46,892
$208,588

$1,376,000
$10,000,000
$5,000
40
5
$74,891
$283,479
$33.4

$2,240
$19,000
$38,000
$1,900
$2,400
6
$14,000
$13,000
$292,640

1500
$35,769
$14,308
$50,077
$342,717
$99,388
$442,105

$1,376,000
$10,000,000
$5,000
40
5
$74,891
$516,997
$34.5

$4,386
$3,800
$75,000
$1,900
$2,400
12
$19,000
$15,000
$736,386

2000
$47,692
$19,077
$66,769
$803,155
$232,915
$1,036,070

$1,376,000
$10,000,000
$5,000
40
5
$74,891
$1,110,962
$23.1
ICF International
EPA Contract EP-C-06-094, WA 2-08
3-12
U.S. Environmental Protection Agency
                     April 20099

-------
          Costs of Emission Reduction Technologies for Category 3 Marine Engines
                                    Economic Impact
                             Table 3-16. DWI Water Tank Costs
 Speed
 Engine Power (kW)
 Cylinders
 Liters/cylinder
 Engine Speed (rpm)

 Water Tank Costs
  Fuel Amount (kg)
  Density (kg/mA3)
  Tank Size (mA3)
  Tank Material (mA3)
  Tank Material Cost ($)
 Assembly
  Labor (hours)
  Cost ($23.85/hr)
  Overhead @ 40%
 Total Assembly Cost
 Total Variable Cost
 Markup @ 29%
 Total Hardware RPE
Medium
4,500
9
35
650
Medium
9,500
12
65
550
Medium
18,000
16
95
500
Low
8,500
6
380
130
Low
15,000
8
650
110
Low
48,000
12
1400
100
86,070
1,000
103
0.13
$711
181,703
1,000
218
0.22
$1,169
344,280
1,000
413
0.33
$1,790
150,964
1,000
151
0.17
$915
266,407
1,000
266
0.25
$1,336
852,503
1,000
853
0.54
$2,899
                            7
                         $167
                          $67
                         $234
                       $2,023
                         $587
                       $2,610

Table 3-17. DWI Distilled Water Costs
5
$119
$48
$167
$878
$255
$1,132
6
$143
$57
$200
$1,370
$397
$1,767
10
$238
$95
$334
$1,249
$362
$1,611
12
$286
$114
$401
$1,737
$504
$2,240
15
$358
$143
$501
$3,400
$986
$4,386
Medium
4,500
9
35
650
Medium
9,500
12
65
550
Medium
18,000
16
95
500
Low
8,500
6
380
130
Low
15,000
8
650
110
Low
48,000
12
1400
100
 Speed
 Engine Power (kW)
 Cylinders
 Liters/cylinder
 Engine Speed (rpm)

 Distilled Water Costs
  BSFC (g/kWh)
  Load factor
  Water/Fuel Ratio
  Water Use (kg/hr)
  Water Cost per kg
  Water cost per hour

3.4.5.  Exhaust Gas Recirculation
Exhaust gas recirculation costs include a supply pump, a sludge tank,  piping, a waste pump, a
recirculation pump, a scrubber unit, a separator, an EGR valve, and the control unit and wiring.
Costs for an EGR system are given in Table 3-18.  Retooling costs are for exhaust system
redesign.  Table 3-19 provide details on the sludge tank.  Sludge is estimated to build up at 0.05
g/kWh with a sludge density of 1,300 kg/m3 based upon an average 20 percent EGR rate. The
sludge tank is envisioned to be constructed of cold rolled steel 1  mm thick. The tank will hold
sludge generated from  500 hours of engine operation.
210
73%
0.50
344
$0.0264
$9
210
73%
0.50
727
$0.0264
$19
210
73%
0.50
1,377
$0.0264
$36
195
73%
0.50
604
$0.0264
$16
195
73%
0.50
1,066
$0.0264
$28
195
73%
0.50
3,410
$0.0264
$90
ICF International
EPA Contract EP-C-06-094, WA 2-08
              3-13
U.S. Environmental Protection Agency
                    April 20099

-------
          Costs of Emission Reduction Technologies for Category 3 Marine Engines
                                     Economic Impact

Speed
Engine Power (kW)
Cylinders
Liters/cylinder
Engine Speed (rpm)
Table 3-1 8.
Medium
4,500
9
35
650
Exhaust Gas
Medium
9,500
12
65
550
Recirculation Costs
Medium
18,000
16
95
500
Low
8,500
6
380
130
Low
15,000
8
650
110
Low
48,000
12
1400
100
Hardware Costs to the Manufacturer
Component Costs
Supply Pump
Sludge Tank
Piping
Waste Pump
Recirculation Pump
Scrubber Unit
Separator
EGR Valve
Control UnitAA/iring
Total Component Cost
Assembly
Labor (hours)
Cost($23.85/hr)
Overhead @ 40%
Total Assembly Cost
Total Variable Cost
Markup @ 29%
Total Hardware RPE
Fixed Costs
R&D Costs (1 year R&D)
Retooling Costs
Marine Society Approval
Engines/yr.
Years to recover
Fixed cost/engine
Total Costs
Cost per kW

$1,900
$268
$2,800
$1,900
$1,900
$23,500
$1,900
$7,000
$4,700
$45,868

200
$4,769
$1,908
$6,677
$52,545
$15,238
$67,783

$688,000
$2,000,000
$5,000
40
5
$17,889
$85,672
$19.0

$2,600
$345
$3,800
$2,800
$2,800
$35,000
$2,800
$9,500
$4,700
$64,345

300
$7,154
$2,862
$10,015
$74,361
$21,565
$95,925

$688,000
$2,000,000
$5,000
40
5
$17,889
$113,814
$12.0

$3,600
$435
$4,700
$3,800
$3,800
$56,000
$3,800
$11,700
$4,700
$92,535

400
$9,538
$3,815
$13,354
$105,888
$30,708
$136,596

$688,000
$2,000,000
$5,000
40
5
$17,889
$154,485
$8.6

$2,600
$511
$3,700
$2,800
$2,800
$32,700
$2,800
$9,500
$4,700
$62,111

300
$7,154
$2,862
$10,015
$72,127
$20,917
$93,044

$688,000
$2,000,000
$5,000
40
5
$17,889
$110,932
$13.1

$4,400
$635
$4,700
$4,700
$4,700
$56,000
$3,800
$11,700
$4,700
$95,335

400
$9,538
$3,815
$13,354
$108,689
$31,520
$140,208

$688,000
$2,000,000
$5,000
40
5
$17,889
$158,097
$10.5

$7,000
$859
$5,600
$7,500
$7,500
$112,200
$4,700
$14,000
$4,700
$164,059

500
$11,923
$4,769
$16,692
$180,751
$52,418
$233,169

$688,000
$2,000,000
$5,000
40
5
$17,889
$251,058
$5.2
ICF International
EPA Contract EP-C-06-094, WA 2-08
3-14
U.S. Environmental Protection Agency
                     April 20099

-------
          Costs of Emission Reduction Technologies for Category 3 Marine Engines
                                    Economic Impact


                                Table 3-19. Sludge Tank Costs
 Speed                       Medium    Medium     Medium      Low        Low        Low
 Engine Power (kW)             4,500      9,500      18,000      8,500      15,000      48,000
 Cylinders                       9         12         16          6          8          12
 Liters/cylinder                  35        65         95        380        650        1400
 Engine Speed (rpm)             650        550        500        130        110        100

 Sludge Tank Costs
 Sludge Rate, g/kWh                0.05       0.05       0.05        0.05        0.05       0.05
 Sludge Amount (kg)              112.50     237.50     450.00      212.50      375.00    1,200.00
 Sludge Tank size (mA3)             0.104      0.219      0.415       0.196       0.346       1.108
   Tank Material (mA3)              0.01       0.01        0.02        0.01        0.01       0.03
   Tank Material Cost ($)             $41        $67       $103        $63        $91       $198
 Assembly
   Labor (hours)                      5         6         7         10         12         14
   Cost($23.85/hr)                 $119       $143       $167       $238       $286       $334
   Overhead @ 40%                $48        $57       $67        $95       $114       $134
 Total Assembly Cost              $167       $200       $234       $334       $401       $467
 Total Variable Cost               $208       $268       $337       $396       $492       $666
 Markup® 29%                    $60        $78       $98       $115       $143       $193
 Total Hardware RPE              $268       $345       $435       $511       $635       $859

3.4.6.  Selective Catalytic Reduction

Selective catalytic reduction (SCR) costs include the urea  tank, the reactor, dosage pump, urea
injectors, piping, bypass  valve, the acoustic horn,  a  cleaning  probe and the  control unit and
wiring. Detailed costs are shown in Table 3-20.  Retooling costs are for redesign of the exhaust
system to accommodate the SCR unit.  Detailed costs for the urea  tank are shown  in Table 3-21
and estimate storage of urea for 250 hours of normal  operation when operating in the emission
control area (EGA).  Because of the corrosive nature of urea, it is envisioned that the urea tank
is constructed of 304 stainless steel 1 mm thick at a cost of $2,747.20 per metric tonne.47 Urea
usage costs  are shown in Table 3-22  and are estimated assuming a  cost of $1.52/gallon for
urea with a density of 1.09 grams per cubic centimeter.
47 http://vwvw.metalprices.com/FreeSite/metals/stainless product/product.asp#Tables for 2006.
ICF International                              3-15             U.S. Environmental Protection Agency
EPA Contract EP-C-06-094, WA 2-08                                                        April 20099

-------
          Costs of Emission Reduction Technologies for Category 3 Marine Engines
                                     Economic Impact
Table 3-20. Selective Catalytic Reduction Costs
Speed
Engine Power (kW)
Cylinders
Liters/cylinder
Engine Speed (rpm)
Medium
4,500
9
35
650
Medium
9,500
12
65
550
Medium
18,000
16
95
500
Low
8,500
6
380
130
Low
15,000
8
650
110
Low
48,000
12
1400
100
Hardware Costs to the Supplier
Component Costs
Aqueous Urea Tank
Reactor
Dosage Pump
Urea Injectors (each)
Number of Urea Injectors
Piping
Bypass Valve
Acoustic Horn
Cleaning Probe
Control UnitAA/iring
Total Component Cost
Assembly
Labor (hours)
Cost ($23.85/hr)
Overhead @40%
Total Assembly Cost
Total Variable Cost
Markup @ 29%
Total Hardware RPE
Fixed Costs
R&D Costs (2 years R&D)
Retooling Costs
Marine Society Approval
Engines/yr.
Years to recover
Fixed cost/engine
Total Costs
Cost per kW

$1,194
$200,000
$9,500
$2,400
3
$4,700
$4,700
$9,500
$575
$14,000
$251,369

1000
$23,846
$9,538
$33,385
$284,753
$82,578
$367,332

$1,376,000
$2,000,000
$5,000
40
5
$22,699
$390,031
$86.7

$1,868
$295,000
$11,300
$2,400
6
$5,600
$5,600
$11,300
$575
$14,000
$359,643

1200
$28,615
$11,446
$40,062
$399,704
$115,914
$515,618

$1,376,000
$2,000,000
$5,000
40
5
$22,699
$538,317
$56.7

$2,765
$400,000
$13,000
$2,400
8
$6,600
$6,600
$13,000
$575
$14,000
$475,740

1500
$35,769
$14,308
$50,077
$525,816
$152,487
$678,303

$1,376,000
$2,000,000
$5,000
40
5
$22,699
$701,002
$38.9

$1,690
$345,000
$11,300
$2,400
12
$5,600
$5,600
$11,700
$700
$19,000
$429,390

1200
$28,615
$11,446
$40,062
$469,452
$136,141
$605,593

$1,376,000
$2,000,000
$5,000
40
5
$22,699
$628,292
$73.9

$2,356
$560,000
$13,000
$2,400
16
$7,500
$6,600
$14,000
$700
$19,000
$661,556

1600
$38,154
$15,262
$53,415
$714,971
$207,342
$922,313

$1,376,000
$2,000,000
$5,000
40
5
$22,699
$945,012
$63.0

$4,636
$1,400,000
$15,000
$2,400
24
$9,500
$7,500
$16,400
$700
$19,000
$1,530,336

2000
$47,692
$19,077
$66,769
$1,597,106
$463,161
$2,060,266

$1,376,000
$2,000,000
$5,000
40
5
$22,699
$2,082,965
$43.4
ICF International
EPA Contract EP-C-06-094, WA 2-08
3-16
U.S. Environmental Protection Agency
                     April 20099

-------
          Costs of Emission Reduction Technologies for Category 3 Marine Engines
                                    Economic Impact
                                 Table 3-21. Urea Tank Costs
 Speed
 Engine Power (kW)
 Cylinders
 Liters/cylinder
 Engine Speed (rpm)

 Urea Tank Costs
   Urea Amount (kg)
   Density (kg/mA3)
   Tank Size (mA3)
   Tank Material (mA3)
   Tank Material Cost ($)
 Assembly
   Labor (hours)
   Cost ($23.85/hr)
   Overhead @ 40%
 Total Assembly Cost
 Total Variable Cost
 Markup @ 29%
 Total Hardware  RPE
Medium
4,500
9
35
650
Medium
9,500
12
65
550
Medium
18,000
16
95
500
Low
8,500
6
380
130
Low
15,000
8
650
110
Low
48,000
12
1400
100
12,910
1,090
14
0.04
$758
27,255
1,090
30
0.06
$1,248
51,642
1,090
57
0.09
$1,909
22,645
1,090
21
0.05
$977
39,961
1,090
37
0.07
$1,426
127,875
1,090
117
0.14
$3,093
                     7
                  $167
                   $67
                  $234
                 $2,143
                  $621
                 $2,765

Table 3-22. Urea Costs
5
$119
$48
$167
$925
$268
$1,194
6
$143
$57
$200
$1,448
$420
$1,868
10
$238
$95
$334
$1,310
$380
$1,690
12
$286
$114
$401
$1,826
$530
$2,356
15
$358
$143
$501
$3,594
$1,042
$4,636
Medium
4,500
9
35
650
Medium
9,500
12
65
550
Medium
18,000
16
95
500
Low
8,500
6
380
130
Low
15,000
8
650
110
Low
48,000
12
1400
100
 Speed
 Engine Power (kW)
 Cylinders
 Liters/cylinder
 Engine Speed (rpm)

 Aqueous Urea Costs
   BSFC (g/kWh)
   Load factor
   Aqueous Urea Rate
   Aqueous Urea (kg/hr)
   Aqueous Urea Cost per kg
   Aqueous Urea Cost per hour

3.4.7.  Sea Water Scrubbers
Sea water scrubber costs include the supply pump, the sludge tank,  piping,  a waste pump, a
recirculation  pump, the scrubber unit, an oil/water separator, an SO2 monitor,  and the control
unit and  wiring.  Retooling costs are for redesign of the exhaust system to accommodate the
scrubber unit.  Detailed costs are given in  Table 3-23.  Detailed costs for the sludge tank are
given in Table 3-24 and assume a sludge buildup rate of 0.25 g/kWh48 and a sludge density of
1,300 kg/m3. The sludge  tank is envisioned to be constructed of cold rolled  steel 1 mm thick.
The tank will hold sludge generated for 500 hours of engine operation.
210
73%
7.5%
52
$0.3684
$19
210
73%
7.5%
109
$0.3684
$40
210
73%
7.5%
207
$0.3684
$76
195
73%
7.5%
91
$0.3684
$33
195
73%
7.5%
160
$0.3684
$59
195
73%
7.5%
512
$0.3684
$188
 1 Entec UK Ltd, "Service Contract on Ship Emissions: Assignment, Abatement and Market Based Instruments - Task
  2c - SO2 Abatement," August 2005 available at http://ec.europa.eu/environment/air/pdf/task2 so2.pdf.
ICF International
EPA Contract EP-C-06-094, WA 2-08
        3-17
U.S. Environmental Protection Agency
                     April 20099

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          Costs of Emission Reduction Technologies for Category 3 Marine Engines
                                     Economic Impact
Table 3-23. Sea Water Scrubber Costs
Speed
Engine Power (kW)
Cylinders
Liters/cylinder
Engine Speed (rpm)
Medium
4,500
9
35
650
Medium
9,500
12
65
550
Medium
18,000
16
95
500
Low
8,500
6
380
130
Low
15,000
8
650
110
Low
48,000
12
1400
100
Hardware Costs to the Supplier
Component Costs
Supply Pump
Sludge Tank
Piping
Waste Pump
Recirculating Pump
Scrubber Unit
Separator
SO2 Monitor
Control UnitAA/iring
Total Component Cost
Assembly
Labor (hours)
Cost($23.85/hr)
Overhead @ 40%
Total Assembly Cost
Total Variable Cost
Markup @ 29%
Total Hardware RPE
Fixed Costs
R&D Costs (1 year R&D)
Retooling Costs
Marine Society Approval
Engines/yr.
Years to recover
Fixed cost/engine
Total Costs
Cost per kW

$9,500
$350
$4,700
$9,500
$9,500
$215,000
$7,000
$9,500
$28,000
$293,050

600
$14,308
$5,723
$20,031
$313,081
$90,794
$403,875

$688,000
$2,000,000
$5,000
40
5
$17,889
$421,763
$93.7

$14,000
$481
$5,600
$11,300
$11,300
$355,000
$8,000
$9,500
$28,000
$443,181

800
$19,077
$7,631
$26,708
$469,888
$136,268
$606,156

$688,000
$2,000,000
$5,000
40
5
$17,889
$624,045
$65.7

$19,000
$641
$6,600
$13,000
$13,000
$550,000
$9,000
$9,500
$28,000
$648,741

1000
$23,846
$9,538
$33,385
$682,126
$197,817
$879,943

$688,000
$2,000,000
$5,000
40
5
$17,889
$897,831
$49.9

$14,000
$637
$5,600
$11,300
$11,300
$340,000
$8,000
$9,500
$28,000
$428,337

1000
$23,846
$9,538
$33,385
$461,722
$133,899
$595,621

$688,000
$2,000,000
$5,000
40
5
$17,889
$613,510
$72.2

$23,500
$818
$7,500
$13,000
$13,000
$500,000
$9,000
$9,500
$28,000
$604,318

1500
$35,769
$14,308
$50,077
$654,395
$189,774
$844,169

$688,000
$2,000,000
$5,000
40
5
$17,889
$862,058
$57.5

$37,500
$1,256
$9,500
$15,000
$15,000
$1,125,000
$10,000
$9,500
$28,000
$1,250,756

2000
$47,692
$19,077
$66,769
$1,317,525
$382,082
$1,699,608

$688,000
$2,000,000
$5,000
40
5
$17,889
$1,717,497
$35.8
ICF International
EPA Contract EP-C-06-094, WA 2-08
3-18
U.S. Environmental Protection Agency
                     April 20099

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          Costs of Emission Reduction Technologies for Category 3 Marine Engines
                                   Economic Impact


                               Table 3-24. Sludge Tank Costs
 Speed                      Medium    Medium    Medium     Low       Low        Low
 Engine Power (kW)             4,500      9,500      18,000      8,500      15,000      48,000
 Cylinders                      9         12         16          6          8         12
 Liters/cylinder                 35        65         95        380        650        1400
 Engine Speed (rpm)             650        550        500       130        110        100

 Sludge Tank Costs
  Sludge Rate, g/kWh             0.25       0.25        0.25       0.25        0.25       0.25
  Sludge Amount (kg)            562.50    1,187.50    2,250.00    1,062.50    1,875.00    6,000.00
  Sludge Tank size (mA3)           0.519      1.096       2.077      0.981       1.731      5.538
  Tank Material (mA3)             0.02       0.03        0.05       0.03        0.04       0.09
  Tank Material Cost ($)            $105      $172       $264      $160       $233      $506
 Assembly
  Labor (hours)                     5         6          7         10         12         14
  Cost ($23.85/hr)                $119      $143       $167      $238       $286      $334
  Overhead @ 40%                $48       $57        $67       $95       $114      $134
 Total Assembly Cost             $167      $200       $234      $334       $401      $467
 Total Variable Cost               $272      $372       $497      $494       $634      $974
 Markup® 29%                   $79      $108       $144      $143       $184      $282
 Total Hardware RPE              $350      $481       $641      $637       $818     $1,256

3.5.  Fuel Switching Hardware  Costs

In this section,  hardware costs related to fuel  switching are discussed.  Fuel cost differentials
have  been discussed  in another EPA report.33  Three cases are discussed in Section  2.3,
namely:

       •   Case 0: Vessels meet all requirements of a EGA and require no  modifications or
          retrofits (baseline).

       •   Case  1:  A newly  built vessel   requires  additional  equipment to  meet   EGA
          requirements over comparable new  vessels.

       •   Case 2: Existing vessels will require retrofits to meet EGA requirements.

Case 0 assumes  that the  vessels have sufficient storage tank capacity currently  for  fuel
switching and all the proper equipment necessary  to accomplish fuel switching in a EGA area.
Based upon  their  survey, ARE estimates that 78 percent of all  ships  fall into  this category.
However,  ARE believes that this is an underestimation and that the vast majority of ships fall
into this category.41 There is no hardware  costs associated with Case 0.

Case 1 assumes that new vessels will be built with  additional distillate fuel storage capacity and
systems over existing ships.  Costs include additional distillate fuel storage tanks, an  LFO fuel
separator, an HFO/LFO blending unit, a 3-way valve, an LFO cooler, filters, a viscosity meter,
and various pumps and piping.  These costs  are  shown in Table 3-25.  Details on additional
tank costs are  shown  in Table 3-26.  Distillate tanks are assumed  to be constructed of  cold
rolled steel 1 mm  thick and double walled and will hold an additional 250 hours of propulsion
and auxiliary engine operation  while within a EGA.
ICF International                             3-19             U.S. Environmental Protection Agency
EPA Contract EP-C-06-094, WA 2-08                                                       April 20099

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           Costs of Emission Reduction Technologies for Category 3 Marine Engines
                                     Economic Impact
Table 3-25. Case 1 Fuel Switching Costs (New Construction)
Speed
Engine Power (kW)
Cylinders
Liters/cylinder
Engine Speed (rpm)
Hardware Cost to Supplier
Component Costs
Additional Tanks
LFO Separator
HFO/LFO Blending Unit
3-Way Valve
LFO Cooler
Filters
Viscosity Meter
Piping/Pumps
Total Component Cost
Assembly
Labor (hours)
Cost($23.85/hr)
Overhead @ 40%
Total Assembly Cost
Total Variable Cost
Markup @ 29%
Total Hardware RPE
Fixed Costs
R&D Costs (0.25 year R&D)
Marine Society Approval
Engines/yr.
Years to recover
Fixed cost/engine
Total Costs
Cost per kW
Medium
4,500
9
35
650


$3,409
$2,800
$4,200
$950
$2,400
$950
$1,400
$2,000
$18,109

240
$5,723
$2,289
$8,012
$26,121
$7,575
$33,696

$172,000
$5,000
40
5
$1,233
$34,929
$7.8
Medium
9,500
12
65
550


$5,511
$3,300
$4,700
$1,400
$2,800
$950
$1,400
$2,000
$22,061

320
$7,631
$3,052
$10,683
$32,744
$9,496
$42,240

$172,000
$5,000
40
5
$1,233
$43,473
$4.6
Medium
18,000
16
95
500


$8,341
$3,800
$5,600
$1,900
$3,300
$950
$1,400
$2,000
$27,291

480
$11,446
$4,578
$16,025
$43,316
$12,562
$55,877

$172,000
$5,000
40
5
$1,233
$57,110
$3.2
Low
8,500
6
380
130


$4,562
$3,800
$4,700
$1,400
$2,800
$950
$1,400
$2,000
$21,612

320
$7,631
$3,052
$10,683
$32,295
$9,366
$41,661

$172,000
$5,000
40
5
$1,233
$42,894
$5.0
Low
15,000
8
650
110


$6,548
$4,200
$5,600
$1,900
$3,800
$950
$1,400
$2,000
$26,398

480
$11,446
$4,578
$16,025
$42,423
$12,303
$54,725

$172,000
$5,000
40
5
$1,233
$55,958
$3.7
Low
48,000
12
1400
100


$13,733
$4,700
$6,600
$2,800
$4,700
$950
$1,400
$2,000
$36,883

600
$14,308
$5,723
$20,031
$56,914
$16,505
$73,419

$172,000
$5,000
40
5
$1,233
$74,652
$1.6
ICF International
EPA Contract EP-C-06-094, WA 2-08
3-20
U.S. Environmental Protection Agency
                     April 20099

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           Costs of Emission Reduction Technologies for Category 3 Marine Engines
                                     Economic Impact


                         Table 3-26. Additional Fuel Tank Storage Costs
       Speed                    Medium   Medium   Medium    Low     Low       Low
       Engine Power (kW)          4,500      9,500     18,000    8,500    15,000     48,000
       Cylinders                    9         12       16        6        8         12
       Liters/cylinder                35         65       95      380     650       1400
       Engine Speed (rpm)          650       550      500      130     110       100

       Propulsion
         BSFC(g/kWh)                 210       210       210      195      195        195
         Load factor                  73%      73%      73%      73%      73%       73%
       Auxiliary
         Power (kW)                 1,022     2,158     4,090     1,931     3,408     10,906
         BSFC(g/kWh)                 227       227       227      227      227       227
         Load factor                  31%      31%      31%      31%      31%       31%
       Combined
         Fuel Amount (kg)           190,001    401,114    760,006   335,666   592,352   1,895,528
         Density (kg/mA3)               960       960       960      960      960       960
         Tank Size (mA3)               238       501       950      350      617      1,975
         Tank Material (mA3)           0.46      0.75      1.15      0.59      0.87       1.88
       Tank Material Cost ($)          $2,476    $4,072    $6,232    $3,203    $4,675    $10,145
       Assembly
         Labor (hours)                    5        6         7        10       12        15
         Cost($23.85/hr)              $119     $143      $167      $238     $286      $358
         Overhead@40%               $48       $57       $67      $95     $114      $143
       Total Assembly Cost           $167     $200      $234      $334     $401      $501
       Total Variable Cost            $2,642    $4,272    $6,466    $3,537    $5,076    $10,646
       Markup® 29%                 $766    $1,239    $1,875    $1,026    $1,472     $3,087
       Total Hardware RPE           $3,409    $5,511    $8,341    $4,562    $6,548    $13,733

Case 2 is for retrofitting ships with equipment to allow fuel switching.  It is similar to Case  1
costs,  however, additional labor is allocated  to installing the systems  on a ship and additional
R&D is provided to test systems on existing ships.  Case 2 costs  are given in Table 3-27.
ICF International                               3-21              U.S. Environmental Protection Agency
EPA Contract EP-C-06-094, WA 2-08                                                           April 20099

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          Costs of Emission Reduction Technologies for Category 3 Marine Engines
                                    Economic Impact
 Speed
 Engine Power (kW)
 Cylinders
 Liters/cylinder
 Engine Speed (rpm)
Table 3-27. Case 2 Fuel Switching Costs (Retrofits)
     Medium
      4,500
       9
       35
       650
 Hardware Cost to Supplier
 Component Costs
  Additional Tanks
  LFO Separator
  HFO/LFO Blending Unit
  3-Way Valve
  LFO Cooler
  Filters
  Viscosity Meter
  Piping/Pumps
 Total Component Cost
 Assembly
  Labor (hours)
  Cost($23.85/hr)
  Overhead @ 40%
 Total Assembly Cost

 Total Variable Cost
 Markup @ 29%
 Total Hardware RPE

 Fixed Costs
 R&D Costs (0.33 year R&D)
 Marine Society Approval
 Engines/yr.
 Years to recover
 Fixed cost/engine

 Total Costs
 Cost per kW
Medium
9,500
12
65
550
Medium
18,000
16
95
500
Low
8,500
6
380
130
Low
15,000
8
650
110
Low
48,000
12
1400
100
$3,409
$2,800
$4,200
$950
$2,400
$950
$1,400
$2,000
$18,109
$5,511
$3,300
$4,700
$1,400
$2,800
$950
$1,400
$2,000
$22,061
$8,341
$3,800
$5,600
$1,900
$3,300
$950
$1,400
$2,000
$27,291
$4,562
$3,800
$4,700
$1,400
$2,800
$950
$1,400
$2,000
$21,612
$6,548
$4,200
$5,600
$1,900
$3,800
$950
$1,400
$2,000
$26,398
$13,733
$4,700
$6,600
$2,800
$4,700
$950
$1,400
$2,000
$36,883
480
$11,446
$4,578
$16,025
$34,133
$9,899
$44,032
640
$15,262
$6,105
$21,366
$43,427
$12,594
$56,021
960
$22,892
$9,157
$32,049
$59,340
$17,209
$76,549
640
$15,262
$6,105
$21,366
$42,979
$12,464
$55,442
960
$22,892
$9,157
$32,049
$58,447
$16,950
$75,397
1200
$28,615
$11,446
$40,062
$76,945
$22,314
$99,259
     $227,040   $227,040   $227,040   $227,040   $227,040   $227,040
       $5,000     $5,000     $5,000     $5,000     $5,000     $5,000
          40        40        40        40         40         40
           555555
       $1,618     $1,618     $1,618     $1,618     $1,618     $1,618

      $45,265    $57,254    $77,782    $56,675    $76,630   $100,492
        $10.1       $6.0       $4.3       $6.7       $5.1       $2.1
3.6.  Differential Fuel Consumption
Fuel consumption increases/decreases were calculated for a 1 percent change in BSFC.  The
values shown  in Table  3-28 can be  scaled up  or down  relative  to  the amount  of  fuel
consumption benefit or penalty.
ICF International
EPA Contract EP-C-06-094, WA 2-08
                     3-22
U.S. Environmental Protection Agency
                     April 20099

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          Costs of Emission Reduction Technologies for Category 3 Marine Engines
                                   Economic Impact


   Table 3-28. Hourly fuel use change estimated for a one percent change in brake specific fuel
                                      consumption

 Speed                       Medium   Medium   Medium   Low    Low    Low
 Engine Power (kW)              4,500      9,500     18,000    8,500   15,000  48,000
 Cylinders                        9        12       16      6       8      12
 Liters/cylinder                    35        65       95     380     650    1400
 Engine Speed (rpm)              650       550       500     130     110    100


 Load Factors, % of hp             73%       73%       73%     73%    73%    73%
 Avg BSFC, g/kWh                 210       210       210     195     195    195

 HFO Fuel Usage Tonnes per hour     0.69       1.45       2.75     1.21     2.13    6.82
3.7.  IMO Testing Costs
IMO testing is done on a representative engine for an engine family. This engine represents the
worst case specification (i.e., the highest NOx emissions).  It is emission tested on a test bed
before sending it to the customer.  Other similar engines are referred to as an engine family and
are not tested.

A  technical file  is submitted with the engine.   It  would  contain  the identification  of  the
components, settings and operating values of the engine that influence NOx  emissions.  The
critical components are marked with I MO-ID  numbers and  relevant parameters are  identified,
providing an easy means of compliance checking  onboard the ship.  Identification  of the full
range of allowable adjustments or alternatives for the components of the engine are also listed
along with a system of onboard NOx verification procedures (component and setting checks) to
verify compliance with the IMO NOx emission limits during onboard verification surveys.

The cost of Marine Society approval is estimated at $5,000.
ICF International                             3-23             U.S. Environmental Protection Agency
EPA Contract EP-C-06-094, WA 2-08                                                      April 20099

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          Costs of Emission Reduction Technologies for Category 3 Marine Engines
                                    Economic Impact
                                              page
ICF International                              3-24             U.S. Environmental Protection Agency
EPA Contract EP-C-06-094, WA 2-08                                                        April 20099

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