2020 Sulphur Cap Compliance: Owners Need Accurate Monitoring

By Dr Brian Phillips, Managing Director, Chelsea Technologies Group first published in Tanker Operator, March 2018

As 2020 0.5% sulphur cap compliance looms, shipowners and operators are left with a short window to decide which path they will take in complying with MARPOL’s Annex VI regulations. Although the reduction in the sulphur content of marine fuel from the current 3.5% has been known since the 20th meeting of the IMO’s Marine Environment Protection Committee (MEPC) in October 2016, many within the industry are adopting a wait and see approach, and given the level of debate around compliance solutions even with this short window, it’s easy to see why.

To ensure compliance with the global sulphur cap, shipowners must weigh up the pros and cons of the three main commonly accepted compliance options – switching from Heavy Fuel Oil (HFO) to distillates, the use of Liquefied Natural Gas (LNG) as a marine fuel, or by installing exhaust gas emission cleaners (scrubbers). There are benefits and disadvantages to each, with the size and age of vessel impacting on suitability. LNG still needs significant investment in infrastructure and bunkering standards and is primarily suited for newbuild vessels. LNG installation also requires substantial upfront capital investment which is unlikely to be an issue for major operators but might influence smaller carriers.

Distillate or distillate-based low sulphur fuel is expected to be the most widespread option, although the future cost and availability of the fuel is unknown. There are also concerns about the commingling characteristics of blended fuels and the impacts on engines.

Scrubbers could be an attractive compliance option that affords the owner/operator the opportunity to continue to burn lower cost HFO. Scrubbers are a costly capital expenditure, with installation costs ranging from $2m - $6m per unit. However, the wide spread between the price of HFO and the more expensive marine gas oil (MGO) means that the cost of installing scrubbers could be recouped in just a few years. Conversely, estimates tagging the fuel spread between HFO and distillates post 2020 range between $150 and $400 per tonne (p/t) depending upon the port, according to Platts and Bloomberg data, which will not be cost effective for a lot of shipowners.

According to Clarkson’s Research, the number of vessels reported to be fitted with scrubbers has risen to 240 as of 1st December 2017. The sentiment among many in the industry is that scrubbing will play a significant role in meeting post-2020 emissions regulations standards. About a third of commercial shipping will install a scrubber system and will continue to burn sulphur fuel oil by 2030, according to a recent report by naval architecture and engineering consultants, Foreship. In January this year Irish Continental Group announced that it had ordered the world's largest cruise ferry by vehicle capacity and it will include scrubbers.

Tankers are well suited to scrubber technology, installed either inline or outside the funnel. Indeed, BP has already installed scrubbing technology on two 80,000t LR2 tankers, and scrubber systems will be installed on seven Inventor Chemical Tankers (ICT) vessels built between 2015 and 2017. In contrast, according to reports Scorpio Tankers may wait until the 2020 cap comes into force before making a decision on scrubbers, citing concerns over the future cost of HFO along with the regulatory risk of environmental discharges.

Amidst all this debate and conjecture, it is crucial for shipowners that they take the best option for their vessels and operations to ensure compliance with the regulations. For those looking to scrubbers as a solution, they will need to fully understand both the regulatory and operational implications, and will need accurate monitoring to ensure compliance with associated regulations.

Wet scrubbers use wash water to ‘clean’ emissions before they are released into the atmosphere. It is this water that must be accurately monitored at all times to avoid discharges that may exceed regulations and damage the environment. If wash water monitoring is not accurate, owners are risking significant fines or even detention.

Chelsea Technologies Group (CTG) has direct experience of compliance and the high standards demanded by regulators. CTG’s Sea Sentry scrubber wash water monitoring system has the capability to accurately measure the required parameters of water in closed loop scrubbers, providing accurate data that proves compliance with wash water regulations.

CTG's Sea Sentry provides a fully autonomous wash water monitoring system which monitors both the water inlet and outlet of wet exhaust gas scrubber systems. The system analyses wash water to ensure that it is compliant with environmental regulations which reduce potentially high levels of contamination in exhaust gas scrubber wash water discharge.

Closed loop scrubber systems present a unique challenge when monitoring water as the recirculation process darkens the water, making it difficult to obtain an accurate PAH measurement.  It is by adapting the monitoring process to not only measure the turbidity and absorbance levels, but to apply these values as a correction to the PAH measurements, that accurate readings can be taken. If the readings are not accurate, owners are risking significant fines or detention for breaching IMO MARPOL Annex VI regulations.

It is essential that crews have a thorough understanding of the regulations, monitoring procedures, and the analysis and interpretation of the data. CTG works closely with shipowners, the leading global scrubber manufacturers and the Exhaust Gas Cleaning System Association to provide operators with the knowledge and expertise they need to operate with the highest level of confidence in their system and in proving compliance under the IMO criteria. Sea Sentry is certified by DNV-GL and ClassNK and is the gold standard solution which measures the polycyclic aromatic hydrocarbon, absorbance, turbidity (to ISO 7027: 1999), temperature and pH of scrubber washwater.

The introduction of the 0.5% sulphur cap represents a significant challenge for the whole of the maritime industry, from refiners and fuel suppliers, charterers, shipping owners and operators and equipment manufacturers. With both LNG and scrubbers requiring a lead-in time for order and installation, shipowners will need to make a decision soon to be ready for 2020. LNG is unlikely to be retrofitted in existing vessels and it may be some time before the composition and availability of distillate fuels is known. The installation of scrubbers will allow tanker operators to continue using existing HFO and benefit from the anticipated spread between the cost of HFO and distillates. But with increasing environmental regulation, accurate monitoring will be essential to provide operators with confidence in the reliability and accuracy of their systems to remain compliant and preserve market opportunities.