1 Paragraph 2.2.4.1
Paragraph 2.2.4.1 reads as follows:
-
"There are engines which, due to their size, construction and delivery schedule,
cannot be pre-certified on a test-bed. In such cases, the engine manufacturer,
shipowner or shipbuilder shall make application to the Administration requesting
an onboard test (see 2.1.2.2). The applicant must demonstrate to the
Administration that the onboard test fully meets all of the requirements of a
test-bed procedure as specified in chapter 5 of this Code. In no case shall an
allowance be granted for possible deviations of measurements if an initial survey
is carried out on board a ship without any valid pre-certification test. For
engines undergoing an onboard certification test, in order to be issued with an
Engine International Air Pollution Prevention (EIAPP) Certificate, the same
procedures apply as if the engine had been pre-certified on a test-bed, subject to
the limitations given in paragraph 2.2.4.2."
Interpretation:
1.1 Engines undergoing an onboard certification test should have a preliminary approved
Technical File, pending the results of the emission test.
1.2 If the result of the emission test does not comply with the applicable
NOx regulation, the engines should be re-adjusted to the compliance
condition originally approved, if any, or the applicant should apply to the flag
Administration for acceptance of further testing.
2 Paragraph 4.4.6.1
Paragraph 4.4.6.1 reads as follows:
Interpretation:
2.1 Paragraph 4.4.6.1 cross references paragraph 4.3.8 which provides guidance for
selection of an engine family. For engines fitted with an SCR system to reduce
NOx emissions, it is recognized that some of the parameters provided may
not be common to all engines within a group, in particular paragraphs 4.3.8.2.3 and
4.3.8.2.4 state that:
2.2 For engines fitted with an SCR system to reduce NOx emissions, the number
and arrangement of cylinders may not be common to all members of the Engine Group. These
parameters may be replaced with new parameters derived from the SCR chamber and catalyst
blocks, such as the SCR space velocity (SV), catalyst block geometry and catalyst
material.
2.3 Thisinterpretation maybe applied to the Engine Familywhere the
applicanthasprovided clear evidence that an Engine Family concept, allowing for
different numbers and arrangements of cylinders, will result in same or lower
NOx emissions of the engines with different cylinder numbers compared to
the NOx emissions of the related parent engine.
3 Paragraph 4.4.6.2
Paragraph 4.4.6.2 reads as follows:
-
"The following parameters and specifications shall be common to engines within an
Engine Group
.1 bore and stroke dimensions;
-
.2 method and design features of pressure charging and exhaust gas system:
-
- constant pressure;
- pulsating system;
-
.3 method of charge air cooling system:
-
.4 design features of the combustion chamber that effect NOx
emission;
-
.5 design features of the fuel injection system, plunger and injection
cam or gas valve which may profile basic characteristics that effect
NOx emission; and
-
.6 rated power at rated speed. The permitted ranges of engine power
(kW/cylinder) and/or rated speed are to be declared bythe manufacturer and
approved by the Administration."
Interpretation:
3.1 For engines fitted with an SCR system to reduce NOx
emissions, it is recognized that some of the parameters provided may not be common to
all engines within a group and that new parameters derived from the SCR chamber and
catalyst blocks may be used instead, such as the SCRspace velocity (SV), catalyst block
geometry and catalyst material.
3.2 While the provisions of paragraph 4.4.6.2.1 should remain common to all
engines within the group, the remaining parameters listed in paragraph 4.4.6.2 may be
replaced by alternative SCR parameters, provided that the applicant is able to
demonstrate that these alternative parameters are suitable for defining the Engine
Group.
3.3 The applicant remains responsible for selecting the parent engine and
demonstrating the basis of this selection to the satisfaction of the Administration.
4 Paragraph 5.10.1
Paragraph 5.10.1 reads as follows:
-
"For every Individual Engine or Parent Engine tested to establish an Engine Family
or Engine Group, the engine manufacturer shall prepare a test report which shall
contain the necessary data to fully define the engine performance and enable
calculation of the gaseous emissions including the data as set out in section 1 of
appendix 5 of this Code. The original of the test report shall be maintained on
file with the engine manufacturer and a certified true copy shall be maintained on
file by the Administration."
Interpretation:
4.1 The "necessary data to fully define the engine performance and enable calculation of
the gaseous emissions" should be incorporated, in accordance with 5.12, from the raw
data units to the cycle weighted NOx emission value in g/kWh. The data set
given under appendix 5 should not be considered definitive and any other test data (i.e.
engine performance or setting data, description of control devices) relevant to the
approval of a specific engine design and/or onboard NOx verification
procedures should also be given. For the engine fitted with SCR, under scheme A, the
parameters listed in sub-paragraphs of paragraph 5.2.2 of IMO resolution MEPC. 291(71)
as amended by resolution MEPC.313(74) should be measured and recorded in the engine test
report. Under scheme B, the exhaust gas temperature at the intended inlet of the SCR
chamber should be determined and recorded in the test report. For dual fuel engines, the
ratio of liquid-to-gas, gas fuel temperature and its measurement point position should
be recorded during the testing.
4.2 With reference to appendix 5 to the Code, it should be further interpreted that:
-
.1 the term "Deviation" as given under "Sheet 3/5, Measurement equipment,
Calibration" refers to the deviation of the analyser calibration and not the
deviation of the span gas concentration; and
-
.2 the "Fuel properties", as given under "Sheet 3/5, Fuel Characteristics, Fuel
properties", should include sufficient data to justify the ISO 8217:2017 grade
(i.e. DMA, DMB, etc.) as given on EIAPP Certificate Supplement 1.9.4 by
considering other additional analysis results for the fuel oil characteristics,
i.e. Cetane index (ISO 4264:2018), carbon residue (ISO 10370:2014).