Page 94: of Maritime Reporter Magazine (September 1999)

ification.' The definition of substantial modification depends on when the ship was built. For those built on or after Jan- uary 1, 2000 substantial modifications are those that could potentially cause the engine to exceed the NOx limits as set out by Regulation 13 of Annex VI. For ships built prior to that date, the engines would not normally have been subject to any emission control measures and hence may have NOx emission rates well above those permitted by Regula- tion 13. In the latter case, the NOx Tech- nical Code requires that the NOx emis- sions be quantified in accordance with the Simplified Measurement Method, as given in the Code, prior to and on com- pletion of those modifications. If the

NOx emission value increases by more than the set allowance, 10 percent or 15 percent depending on test conditions, then that engine as modified thereafter falls within the scope of the Annex VI requirements and will therefore need to meet the relevant NOx limit as set out in

Regulation 13, be provided with an approved Technical File and be subject to subsequent surveys.

Consequently, from January 1, 2000 shipowners contemplating modifica- tions to those engine components or set- tings (i.e. combustion chamber geome- try, oil fuel injection arrangements or charge air system) which could affect the NOx emission value will need to take particular care as to the effect of fiMSHS_ GOVERNOR CONTROL SYSTEMS, INC. > GROUP OF COMPANIES

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Circle 245 on Reader Service Card 92 Circle 271 on Reader Service Card those modifications as to an engine': status as regards Annex VI. In the cast of engines on ships built before Januan 1, 2000, it should be recognized that the possible need to perform two sets ol emission measurements onboard and gc through the attendant approvals process is one that should not be undertaken lightly.

Uniformity of Approach

The certification aspects resulting from these NOx controls will be the responsibility of the Flag State of the ship on which an engine is, or will be installed. But, as with other MARPOL work, the administrations may delegate that work to other organizations, which are able to act on their behalf. It is of great importance to both engine builders and shipowners to have a unified proce- dure for this certification on a world- wide basis. Not only will this reduce the difficulty in reaching common interpre- tations of aspects within the regulations but also simplifies matters where change of Flag is undertaken. Currently, the bulk of the work associated with the

NOx controls is being undertaken by the classification societies, which, through

IACS, have a ready means of achieving common agreement between them- selves. This matter of agreement is cru- cial since if there were to be irreconcil- able differences in approach between the various organizations issuing the certification then the smooth operation of the whole system would be impossi- ble. Consequently, it may be seen that the widespread delegation of this NOx certification work to the classification societies would be an effective way of providing the essential uniformity of approach. With all this work associat- ed with the introduction of NOx emis- sion controls, particularly since it addresses matters, which historically have not been of concern to the marine industry, it is to be expected that any number of questions will arise from and between Administrations, classification societies, engine builders, shipowners and others. The CIMAC Exhaust Emis- sion Controls Working Group, as a cross industry forum involved in these matters consequently anticipates a busy and pro- ductive future.

Mr. Andrew Wright from the American

Bureau of Shipping is currently Chair- man of the CIMAC Exhaust Emission

Control (Piston Engines) Working

Group. Working within ABS' London based Engineering Services Department he has a central role in the development and provision of the Bureau's engine certification services to meet the MAR-

POL Annex VI requirements.

Maritime Reporter/Engineering News