North American and U.S. Caribbean
Sea ECA -
Understanding Compliance Issues
a
This document addresses Annex VI compliance issues for a range
of circumstances. Please note that this discussion is not meant
to address every possible circumstance for the topics covered. Vessel
operators are encouraged to contact EPA or U.S. Coast Guard before
applying these responses for a particular set of circumstances.
Exhaust Gas Cleaning Systems (EGCS)
Keeping in mind application of the International Maritime Organization's (IMO)
Resolution MEPC.259(68) 2015 Guidelines for Exhaust Gas Cleaning Systems
(EGCS), what are U.S. EPA requirements for the disposal of sludge from an
EGCS?
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Sludge or residues generated in treating exhaust gas scrubber washwater discharge
t: must not be discharged in waters subject to the VGP (i.e., including waters of the
< territorial sea up to a distance of three miles) and should be delivered ashore to ad-
equate reception facilities. VGP 2.2.26. The United States further expects MARPOL
Annex VI Regulation 4 equivalency approvals to be conditioned upon compliance
with IMO guidelines, including IMO's 2015 Guidelines for Exhaust Gas Cleaning
Systems. See Regulation 4.3. The 2015 Guidelines at 10.4 explain that EGCS resi-
dues should not be discharged to the sea, and Annex VI prohibits incineration on
board.
For open loop EGCS, will EPA consider the effluent pH value based on a
calculation (i.e., computational fluid dynamics) as described in IMO Resolution
MEPC.259(68) 2015 Guidelines for Exhaust Gas Cleaning Systems?
EPA clarified in the response to comments for the 2013 VGP that a computational
calculation is not an approved method for demonstrating compliance with Vessel
General Permit (VGP) pH requirements. (RTC, p.981).
Jk United States
Environmental Protection
^1 Agency
Office of Transportation and Air Quality
EPA-420-F-16-055
December 2016
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For discharges of scrubber wash water effluent from open loop EGCS outside three miles but
within an ECA, has EPA developed any additional requirements for scrubber wash water
effluent pH outside the area where the VGP applies?
EPA has not established requirements that apply to scrubber washwater effluent beyond the re-
quirements implemented through the VGP. However, as noted above, the United States expects
Regulation 4 equivalency approvals to be conditioned upon compliance with IMO guidelines,
including IMO's 2015 Guidelines for Exhaust Gas Cleaning Systems. See Regulation 4.3.
What are EPA concerns with the measurement of polycyclic aromatic hydrocarbons (PAH),
turbidity and temperature in the effluent from the EGCS?
As part of EPA's development of its 2013 VGP, the Agency evaluated EGCS washwater dis-
charges and prepared a report summarizing our findings. That EPA report, "Exhaust Gas Scrub-
ber Washwater Effluent", EPA-800-R-11-006, November 2011, is available online and provides
a discussion of those pollutants and monitoring of those pollutants. EPA expects to continue to
assess the monitoring of these pollutants over the life of the permit. See, http://nepis.epa.gov/
Exe/ZyPDEcgi/P 100DCM Y. PDF ?Dockey=P100DCM Y.PDE
Does the EPA require the effluent from EGCS to be treated?
The 2013 VGP requires EGCS effluent to meet certain numerical discharge limitations. The
permit does not specify how the operator is to meet these limitations, although, EPA expects
that in most instances, compliance with the numeric limitations cannot be achieved except
through treatment. Also, as specified in Part 2 of the VGP, vessel operators cannot use dilution
as a substitute for treatment for the purpose of meeting effluent limitations.
What concerns does the EPA have for the reliability, calibration and maintenance of the
continuous emission monitoring equipment?
We do not have concerns about the reliability, calibration, and maintenance of the continuous
emission monitoring equipment. Specifications are set out in IMO's scrubber guidelines, and
measurement equipment meeting the appropriate specifications is commercially available today.
The VGP requires that this equipment be calibrated as recommended by the equipment manu-
facturers. At a minimum, this means at least annual calibration although EPA acknowledges
that it may be much more frequent.
Low Sulfur Fuel Requirements—Dual-fuel engines
The European Union (EU) recently allowed for LNG Carriers to use a mixture of 0.50 %
Sulfur Heavy Fuel Oil (HFO) pilot fuel and LNG boil off gas ("BOG") as an equivalent
within the EU SEC As. Will EPA consider a similar concept for LNG Carriers to operate
within North American and Caribbean ECAs?
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out extra NOx control equipment. On such engines, some exceptions to gas mode operation will
occur that require using liquid fuel. What is the acceptability of the following short-term and
infrequent situations involving operation in liquid fuel mode at a Tier II NOx level with foreign
vessels? (i.e., the normally Tier III gas fueled vessel would not need to fit additional NOx control
equipment for liquid fuel mode):
i. Starting and stopping a four-stroke dual-fuel engine in liquid fuel mode.
Any operation of an engine, where that engine deviates from its emission control
strategy, is considered an Auxiliary Control Device (ACD) and must be disclosed
when applying for engine certification (See Annex VI Regulations 2.4, 2.13, and
13.9). This includes the operation of a dual fuel or gas-fueled engine on liquid fuel
during starting, stopping low load operation, and maneuvering and reversing opera-
tions (see MPEC.l/Circ.854, 1 July 2015). Consideration of ACDs for approval will
be handled on a case-by-case basis during the certificate approval process.
ii. Stern propulsion, i.e., reversing the engine, in the liquid mode. Reversing is done
for short periods during braking and maneuvering of direct drive ships.
See above response.
iii. Maneuvering in low load operations (i.e., below 10 % engine load).
See above response.
iv. Vessels transiting to/from shipbuilding or ship repair facilities which do not have
access to LNG.
In situations immediately following building, before or after dry docking, or when
repairs or maintenance are done on board the ship, when a ship is required to be in
a "gas free" condition due to safety requirements, we may allow the ship to proceed
to or from the shipyard, dry dock, or other maintenance location using liquid fuel,
without associated Tier III NOx controls. See MEPC.l/Circ.854 (1 July 2015), para.
8. Permission must be granted before the vessel operates in a NOx ECA; requests will
be considered on a case-by-case basis.
v. Delays to vessels that may lead to all gas fuel being consumed (for example, port
is closed by authorities due to an emergency / bad weather and the vessel cannot
bunker more LNG until alongside a terminal.
In general, a ship operator is expected to have enough LNG and other compliant
fuel onboard to comply with the Tier III NOx standard as well as the ECA fuel sulfur
limits during the anticipated voyage through the ECA. Depending on the sulfur con-
tent of the fuel used and how the engine was certified (whether they were certified to
meet Tier III only on gas fuel), use of liquid fuel could result in noncompliance with
both SOx and NOx standards. The USG would address these potential violations on
a case-by-case basis.
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NOxTier III —Other issues
Will USCG and EPA accept a NOx emission averaging scheme?
No. NOx averaging schemes are not allowed; all engines on-board a ship must comply with the
Regulation 13 NOx standards.
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General Question
Are there additional emission requirements for a vessel owner that wants to change from be-
ing a foreign-flagged vessel to being US-flagged?
A vessel owner who wants to re-flag to the United States should ask USCG to clarify what must
be done to bring that ship into compliance with U.S. laws and requirements. To obtain the
required IAPP, all engines above 130 kW installed on the ship must have an EPA-issued EIAPP;
EPA may issue this based on the original certification test data for the engine showing that it is
in its certified configuration. In addition, if a vessel is converted to be U.S.-flagged, all marine
engines installed on the vessel are subject to all the provisions of 40 CFR part 1042, which may
require that all those engines also be certified to EPA engine emission standards.
For More Information
You can find additional information about EPA and Annex VI requirements on EPA's Office of
Transportation and Air Quality (OTAQ) Web site at:
www.epa.gov/regulations-emissions-vehicles-and-engines/regulations-emissions-
marine-vessels
www.epa.gov/regulations-emissions-vehicles-and-engines/epa-collaboration-interna-
tional-air-pollution-standards
www.epa.gov/regulations-emissions-vehicles-and-engines/guidance-documents-
related-emissions-control-areas-marine
You may also contact U.S. Coast Guard and EPA directly as follows:
U.S. Coast Guard Headquarters
Office of Commercial Vessel Compliance
Domestic Compliance Division
2703 Martin Luther King Jr. Ave. SE, Mail Stop 7501
Washington, DC 20593-7501
Phone: (202) 372-1224
Fax: (202) 372-1917
E-mail: HQS-PF-FLDR-CG-CVC@uscg.mil
U.S. Environmental Protection Agency
Office of Transportation & Air Quality
Compliance Division
E-mail: complianceinfo@epa.gov
1 Engines instaffed on U.S. vessefs must comply with 40 CFR part 1042, which allows for operating at a
reduced level of emission control outside of EC A boundaries. This provision also requiresmanufacturers
to design their engines in a way that makes it impossible to operate at the reduced level of emission
control within EC A boundaries. All questions about exceptions for dual-fuel engines described in this
Question 1 therefore do not apply for U.S. vessels.
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