System malfunction
1 An Exhaust Gas Cleaning System (EGCS) malfunction is any condition that leads to an
emission exceedance, with the exception of the short-term temporary emission exceedance
cases described in sections 7 and 8, or an interim indication of ongoing compliance in
the case of sensor failure described in sections 9 to 11.
2 As soon as possible after evidence of a malfunction (e.g. alarm is triggered), the
ship should take action to identify and remedy the malfunction.
3 The ship operator should follow the process to identify and remedy the malfunction in
the Exhaust Gas Cleaning System – Technical Manual that is approved at the time the EGCS
is certified or in other documentation provided by the EGCS manufacturer.
4 The trouble-shooting process specified by the EGCS manufacturer should describe how to
determine, within a reasonable amount of time, if the system itself is not working
properly and whether the system fault must be addressed through adjustment and/or
repair. The procedure would describe events that can trigger a monitoring alarm or other
evidence of a scrubber malfunction (e.g. pump flow rates) and the troubleshooting
process to identify and remedy the malfunction. The process should include at a minimum
the following:
5 An EGCS malfunction event should be recorded in the EGCS Record Book including the
date and time the malfunction began, the duration of the malfunction and, if relevant,
how it was resolved, the actions taken to resolve it and any necessary follow-up
actions.
6 A system malfunction that cannot be rectified is regarded as a breakdown. The ship
should then change over to compliant fuel oil if the EGCS cannot be put back into a
compliant condition within a maximum of one hour. If the ship does not have compliant
fuel oil or sufficient amount of compliant fuel oil on board, a proposed course of
action, in order to bunker compliant fuel oil or carry out repair works, should be
communicated to relevant authorities including the shipʹs Administration and relevant
port State for their agreement.
Short-term exceedances
7 A short-term temporary emission exceedance is an event where the maximum applicable
Emissions Ratio is exceeded for a short period. This short period of non-compliance may
be due to sudden changes in exhaust gas flow rate or the EGCS's sensor dynamic response.
A time lapse between when the sensor takes its reading and when the unit responds may
trigger an alarm from the continuous emission monitoring device even though the EGCS has
not malfunctioned. Thus, transitory periods of emission exceedances and/or isolated
spikes in the recorded output in the Emissions Ratio do not necessarily mean
non-compliant exceedance of emissions and should therefore not be considered as a breach
of the requirements.
8 The typical operating conditions that may result in a short-term temporary emission
exceedance and the limits of these exceedances should be specified by the EGCS
manufacturer in the EGCS Technical Manual that is approved at the time the EGCS is
certified.
Interim indication of ongoing compliance in the case of sensor failure
9 When running on a fuel oil with a constant sulphur content and at constant washwater
flow rate to engine load ratio, all parameters monitored according to the EGCS
Guidelinesfootnote (i.e. Emission Ratio, washwater pH, etc.) will be in a
certain interrelation, all depending on each other. If one of the parameters changes
significantly, some other(s) may also have to change.
10 This interrelation also serves as an indicator of instrumentation malfunction; i.e.
if a single sensor signal starts to deviate or even does not display, the effect on the
other parameters may indicate whether the change in signal is caused by sensor failure
or whether the performance of the EGCS itself has changed. If the other parameters are
continuing at normal levels, it is a possible indication that there is only an
instrumentation malfunction rather than a non-compliance with regard to the levels
allowed in the exhaust gas and the discharge water.
11 If a malfunction occurs in the instrumentation for the monitoring of Emission Ratio
or discharge water (pH, PAH, Turbidity), the ship should keep records of interim
indication for demonstrating compliance. The documentation and actions should include
(but are not limited to):
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.1 the manual or automatic recording of the data at the time of malfunction may be
used to confirm that all other relevant data as recorded for the performance of
the EGCS are showing values in line with values prior to the malfunction;
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.2 the ship operator should record the sulphur content of the various grades of
fuel oil used in the affected fuel oil combustion units from the time when the
malfunction started;
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.3 the ship operator should log the malfunctioning of the monitoring equipment and
(for Scheme A) record all parameters that might be suitable to indicate compliant
operation. This record could serve as an alternative documentation demonstrating
compliance until the malfunction is rectified; and
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.4 the monitoring equipment that has suffered a malfunction should be repaired or
replaced as soon as practicable.
Notifications to relevant Authorities
12 Any EGCS malfunction that lasts more than one hour or repetitive malfunctions should
be reported to the Flag Administration and the port Stateʹs Administration along with an
explanation of the steps the ship operator is taking to address the failure. At their
discretion, the Flag Administration could take such information and other relevant
circumstances into account to determine the appropriate action to take in the case of an
EGCS malfunction. Should the ship exceptionally need to continue on its intended voyage
in a non-compliant condition, this should be communicated to the relevant port State to
decide on appropriate action in accordance with the Convention.