SUB-COMMITTEE ON SHIP DESIGN AND EQUIPMENT

45th session

Agenda item 4

12 December 2001

Original: ENGLISH

For reasons of economy, this document is printed in a limited number. Delegates are kindly asked to bring their copies to meetings and not to request additional copies.

　

Executive summary:	This document provides a collation of comments and proposals for further developing a set of guidelines for on-board NOx monitoring and recording devices for demonstrating compliance with MARPOL Annex VI, Regulation 13.
Action to be taken:	Paragraph 9
Related documents:	DE 44/19, paragraphs 10.5-10.15; NOx Technical Code; MARPOL Annex VI; DE 44/10; DE 44/TNF.5; DE 42/10/1 ; DE 42/10/2

　

1　The Sub-Committee agreed at its 44th session to further consider the issue of developing guidelines for on-board NOx monitoring and recording devices and established the following terms of reference for the correspondence group:

　

	.1		to collate any information received and prepare draft Guidelines for on-board NOx monitoring and recording devices, taking into account discussions in plenary, documents DE 44/10 and DE 44/INF.5 and the results of the drafting group at the session; and
	.2		to submit a report to DE 45, attaching the draft Guidelines for further consideration.

　

2　The following countries and organizations participated in the correspondence group: Germany, Japan, Panama, the United Kingdom, the United States, EUROMOT, and the International Chamber of Shipping (ICS).

　

3　To initiate the correspondence group efforts toward developing draft guidelines, members were requested to submit proposals and comments in accordance with the seven areas identified by the drafting group in DE 44/WP.5. The seven areas are:

　

	.1		Definition of continuous NOx monitoring, taking into account both steady state and transitional operations of the engine .
	.2		Data recording processing and retention.
	.3		Specification for the equipment to ensure that its reliability is maintained during service.
	.4		Specification for environmental testing of the device.
	.5		Specification for the testing of the equipment to demonstrate that it has a suitable accuracy, repeatability and cross sensitivity compared with the applicable sections of this Code.
	.6		Form of the approval certificate to be issued by the Administration.
	.7		Other aspects not covered above .

　

　4 Four basic proposals were submitted and are contained in Annex l . These four proposals could be described as follows:

　

	.1		one proposal contained draft guidelines that were more specific and equipment-oriented;
	.2		a second proposal recommended that the guidelines should be structured in a similar manner to chapter 5 (as well as chapters 2 and 3 , together with appendices 3, 4, and 6) of the NOx Technical Code;
	.3		a third proposal recommended guidelines for a performance-oriented continuous emissions monitoring system that would allow for use of new technologies; and
	.4		a fourth proposal expressed the view that the guidelines to be developed should avoid specific details and mainly . be a "check list" for Administrations when approving a device as suitable for the foreseen purpose. This proposal maintained that guidelines must not be a vehicle to introduce new mandatory requirements for the onboard verification of compliance and that guidelines must not specify a certain device but rather the necessary performance of suitable devices.

　

　5 Additionally, members submitted comments on the various proposals listed above as well as comments of a general nature. These comments are contained in Annex 2.

　

　6 In conducting the correspondence group effort, the group went through three iterations of comments and proposals while attempting to develop guidelines. While no specific set of guidelines was agreed upon, four basic proposals for guidelines that are listed above have emerged from this effort.

　

　7 There were also several areas where the correspondence group had basic differing views and these need further discussion. They include:

　

	.1		whether the guidelines should monitor NOx emissions during both steady-state and transition operations or only during steady-state operations;
	.2		the definition of continuous monitoring and the frequency of sampling. The views expressed by the members of the correspondence group included: 1 ) monitoring during the 30-day period before a survey; 2) monitoring every 30 days; and 3) continuous monitoring to be understood in the narrow sense and that samples should be taken more frequently over the full range of engine operations;
	.3		whether the guidelines should be more prescriptive-oriented, performance-oriented, or whether the guidelines should only provide a check list for Administrations to assist them in approving such devices.
	.4		whether the NOx Technical Code should be revised to reflect the guidelines eventually developed, depending on the nature of any guidelines developed, and if there are any mandatory items to come from the guidelines such as data process algorithms, and frequency of reporting.

　

8　Given that this correspondence group represents the first time that there has been any in-depth discussion on the development of any such guidelines and recognizing that there was no consensus at this juncture, it is strongly recommended that a working group be established at DE 45 for further development of these guidelines.

　Action requested of the Sub-Committee

　

9　The Sub-Committee is invited to consider the above comments as well as the collation of comments and proposals for guidelines in annexes 1 and 2 and forward these, and discussions from the Sub-Committee, to a working group for further development.