The guidelines to be developed by IMO should be in accordance with the provisions of paragraph 2.4.5 of the NOx Technical Code, which is explicitly referred to in MARPOL Annex VI. According to paragraph 2.4.5, the guidelines are to include:

　

	-		a definition of continuous NOx monitoring, taking into account both steady-state and transition operations of the engine ;
	-		data recording, processing, and retention;
	-		a specification for the equipment to ensure that its reliability is maintained during service ;
	-		a specification for environmental testing;
	-		a specification for testing of the equipment to demonstrate that it has suitable accuracy, repeatability and cross-sensitivity; and
	-		a model form of the type approval certificate to be issued by the Administration.

　

In developing guidelines for NOx monitoring and recording devices priority should be given to the development of a definition of continuous NOx monitoring and the specification for the equipment to ensure the reliability of the equipment, and possibly data recording, processing, and retention.

　

　

Continuous monitoring system means the total equipment used to sample to analyze, and to provide a permanent record of emissions or process parameters.

　

Malfunction means any sudden, infrequent, and not reasonably preventable failure of air pollution control equipment, process equipment, or a process to operate in a normal or usual manner. Failures that are caused in part by poor maintenance or careless operation are not malfunctions.

　

Monitoring device means the total equipment used to measure and record (if applicable) process parameters.

　

One-hour period means any 60-minute period commencing on the hour. Vessel owner or operator means any person who owns, leases, operates, controls, or supervises a marine vessels subject to these guidelines.

　

Shutdown means the cessation of operation of an engine for any purpose.

　

[Time] period means any one of the [number] equal parts of a one-hour period.

　

　

　

8.1.1　Any vessel owner subject to the provisions of these guidelines should maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the operation of the engine; any malfunction of the air pollution control equipment; or any periods during which a continuous monitoring system or monitoring device is inoperative.

　

8.1.2　Vessel owners should cheek the zero and span.

　

8.1.3　Except for system breakdowns, repairs, calibration checks, and zero and span adjustments required under paragraph 2.3, all continuous monitoring systems should be in continuous operation and should complete a minimum of one cycle of operation (sampling, analyzing, and data recording) for each successive [time period].

　

8.2.1　All continuous monitoring systems or monitoring devices should be installed such that representative measurements of emissions or process parameters from the affected vessel are obtained.

　

8.2.2　When the effluents from a single engine or two or more engines subject to the same emission standards are combined before being released to the atmosphere, the vessel owner may install applicable continuous monitoring systems on each effluent or on the combined effluent. When the engines are not subject to the same emission standards, engine data should be collected separately and engine emission data should not be mixed. When the effluent from one engine is released to the atmosphere through more than one point, data should be collected at each point unless otherwise approved by the Administration. When data is collected from more than one point, the vessel owner should report the results from each data point.

　

　

　

　

　

　

Data from all continuous monitoring systems for measurement should be reduced based on a [time period] cycle.

　

　

8.8.1　Method A: Direct NOx measurement method via fuel-specific emissions multiplied by an engine's test-cycle weighted brake-specific fuel consumption. [needs to be completed]

　

8.8.2　Data process algorithm - Method B [needs to be completed]

　

8.8.3　Data process algorithm - Method C [needs to be completed]

　

　

　

　

Excess Emissions Reports: An excess emissions and monitoring systems performance report and/or summary report should be submitted to the Administration every [time period], except when more frequent reporting is specifically required or the Administration determines that more frequent reporting is necessary to accurately assess the compliance status of the engine. [Details of excess emissions reports to be developed later].

　

　

8.12.1　Any vessel owner subject to these continuous monitoring guidelines should maintain a file of all measurements, including continuous monitoring system, monitoring device, and performance testing measurements; all continuous monitoring system performance evaluations; all continuous monitoring system or monitoring device calibration checks; adjustments and maintenance performed on these systems or devices; and all other information required by this part recorded in a permanent form suitable for inspection. The file should be retained for at least [time period] following the date of such measurements, maintenance, reports, and records, except as follows:

　

8.12.2　This paragraph applies to a continuous emissions monitoring system (CEMS) where the CEMS installed is automated, and where the calculated data averages do not exclude periods of CEMS breakdown or malfunction. An automated CEMS records and reduces the measured data to the form of the pollutant emission standard through the use of a computerized data acquisition system. In lieu of maintaining a file of all CEMS measurements, the vessel owner should retain the most recent consecutive [number] averaging period of measurements and a file that contains a hard copy of the data acquisition system algorithm used to reduce the measured data into the reportable form of the standard.

　

8.12.3　This paragraph applies to a CEMS where the measured data is manually reduced to obtain the reportable form of the standard, and where the calculated data averages do not exclude periods of CEMS breakdown or malfunction. In lieu of maintaining a file of all CEMS measurements, the vessel owner should retain all measurements for the most recent reporting period. The measurements should be retained for [time period] from the date of the most recent summary or excess emission report submitted to the Administration.

　

8.12.4　The Administration, upon notification to the vessel owner, may require the vessel owner to maintain all measurements if the Administration determines these records are required to more accurately assess the compliance status of the affected engine.

　

　

　

9.1　At all times, including periods of startup, shutdown, and malfunction, a vessel owner or operator should, to the extent practicable, maintain and operate any affected vessel including associated air pollution control equipment, in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used should be based on information available to the Administration that may include, but is not limited to, monitoring results, review of operating and maintenance procedures, and inspection of the engine.

　

9.2　Vessel owners or operators subject to the provisions of this guidance should not build, erect, install, or use any article, machine, equipment or process, the use of which conceals an emission which would otherwise constitute a violation of an applicable standard. Such concealment includes, but is not limited to, the use of gaseous diluents to achieve compliance with a standard which is based on the concentration of a pollutant in the gases discharged to the atmosphere.

　

　

　

9.4.1　The QA procedures consist of two distinct and equally important functions. One function is the assessment of the quality of the CEMS data by estimating accuracy. The other function is the control and improvement of the quality of the CEMS data by implementing QC policies and corrective actions. These two functions form a control loop: When the assessment function indicates that the data quality is inadequate, the control effort should be increased until the data quality is acceptable. In order to provide uniformity in the assessment and reporting of data quality, this procedure explicitly specifies the assessment methods for response drift and accuracy.

　

9.4.2　Because the control and corrective action function encompasses a variety of policies, specifications, standards, and corrective measures, this procedure treats QC requirements in general terms to allow each vessel owner or operator to develop a QC system that is most effective and efficient for the circumstances.

　

　

9.5.1　Continuous emission monitoring system. The total equipment required for the determination of a gas concentration or emission rate.

　

9.5.2　Diluent gas. A major gaseous constituent in a gaseous pollutant mixture. For determining compliance with Annex VI, Regulation 13, NOx limits, NOx is the major gaseous constituent of interest.

　

9.5.3　Span value. The upper limit of a gas concentration measurement range that is specified for affected engine in [need something here].

　

9.5.4　Zero, low-level, and high-level values. The CEMS response values related to the engine specific span value. Determination of zero, low-level, and high-level values is defined [to be developed].

　

9.5.5　Calibration drift (CD). The difference in the CEMS output reading from a reference value after a period of operation during which no unscheduled maintenance, repair or adjustment took place. The reference value may be supplied by a cylinder gas, gas cell, or optical filter and need not be certified.

　

9.5.6　Relative accuracy (RA). The absolute mean difference between the gas concentration or emission rate determined by the CEMS and the value determined by the RM's plus the 2.5% error confidence coefficient of a series of tests divided by the mean of the RM tests or the applicable emission limit.

　

　

9.6.1　Each vessel owner or operator should develop and implement a QC program.

　

9.6.2　Each QC program should include written procedures which should describe in detail, complete, step-by-step procedures and operations for each of the following activities:

　

	.1		Calibration of CEMS.
	.2		CD determination and adjustment of CEMS
	.3		Preventive maintenance of CEMS (including spare parts inventory)
	.4		Data recording calculations and reporting
	.5		Accuracy audit procedures including sampling and analysis methods.
	.6		Program of corrective action for malfunctioning CEMS.

　

9.6.3　Whenever excessive inaccuracies occur for [time period] , the vessel owner or operator should revise the current written procedures or modify or replace the CEMS to correct the deficiency causing the excessive inaccuracies.

9.6.4　These written procedures should be kept on record and available for inspection by the enforcement authority.

　

　

9.7.1　CD requirement. Vessel owners and operators of CEMS should check, record and quantify the CD at two concentration values.

　

9.7.2　Recording requirement for automatic CD adjusting monitors. Monitors that automatically adjust the data to the corrected calibration values (e.g. microprocessor control) should be programmed to record the unadjusted concentration measured in the CD prior to resetting the calibration, if performed, or record the amount of adjustment.

　

9.7.3　Criteria for excessive CD.

　

9.7.4　Out-of-control period definition.

　

9.7.5　CEMS data status during out-of-control period. During the period the CEMS is out-of-control, the CEMS data should not be used in calculating emission compliance nor be counted towards meeting minimum data availability.

　

9.7.6　Data recording and reporting. All measurements from the CEMS should be retained on file by the vessel owner for at least [time period]. However, emission data obtained on each successive day while the CEMS is out-of-control should not be included as part of the minimum daily data requirement nor be used in the calculation of reported emissions for that period.

　

　

9.8.1　Auditing requirements

　

	.1		Relative accuracy test audit (RATA). The RATA should be conducted on a regular basis at least once every [time period]. A vessel owner may also be requested to analyze the appropriate performance audit samples received from the Administration.
	.2		Cylinder gas audit (CGA). If applicable, a CGA may be conducted. To conduct a CGA:
		.2.1	Challenge the CEMS (both pollutant and diluent portions of the CEMS, if applicable) with an audit gas of known concentration at two points within the following ranges. Challenge the CEMS three times at each audit point, and use the average of the three responses in determining accuracy. Use of separate audit gas cylinder for audit points 1 and 2 . Do not dilute gas from audit cylinder when challenging the CEMS. The monitor should be challenged at each audit point for a sufficient period of time to assure adsorption-desorption of the CEMS sample transport surfaces has stabilized.

		.2.2	Operate each monitor in its normal sampling mode, i.e., pass the audit gas through all filters, scrubbers, conditioners, and other monitor components used during normal sampling, and as much of the sampling probe as is practical. At a minimum, ~the audit gas should be introduced at the connection between the probe and the sample line.
		.2.3	Use audit gases that have been certified by [to be completed].
	.3		Relative accuracy audit (RAA). The RAA should be conducted on a regular basis at least once every [time period] . To conduct a RAA, follow the procedure [to be developed] . Analyses of performance audit samples should also be considered. The relative difference between the mean of the RM values and the mean of the CEMS responses should be used to assess the accuracy of the CEMS.
	.4		Other alternative audits. Other alternative audit procedures may be used as approved by the Administration for [time period]. One RATA should be performed at least once every [time period].

　

9.8.2　Excessive audit inaccuracy. If the RA, using the RATA, CGA, or RAA exceeds the criteria in section 5.2.3, the CEMS is out-of-control. If the CEMS is out-of-control, corrective action should be taken to eliminate the problem. Following corrective action, the vessel owner or operator should audit the CEMS with a RATA, CGA, or RAA to determine if the CEMS is operating within the specifications. A RATA should always be used following an out-of-control period resulting from a RATA. The audit following corrective action does not require analysis of performance audit samples. If audit results show the CEMS to be out-of-control, the CEMS operator should report both the audit showing the CEMS to be out-of-control and the results of the audit following corrective action showing the CEMS to be operating within specifications.

　

9.8.2.1　Out-of-control period definition. The beginning of the out-of-control period is the time corresponding to the completion of the sampling for the RATA, RAA, or CGA. The end of the out-of-control period is the time corresponding to the completion of the sampling of the subsequent successful audit.

　

9.8.2.2　CEMS data status during out-of-control period. During the period the monitor is out-of-control, the CEMS data should not be used in calculating emission compliance nor be counted towards meeting minimum data availability as required and described in the applicable subpart.

　

9.8.2.3　Criteria for excessive audit inaccuracy. Unless specified otherwise in the applicable subpart, the criteria for excessive inaccuracy are: [needs to be completed]

　

9.8.3　Criteria for acceptable QC procedure. Repeated excessive inaccuracies (i.e., out-of-control conditions resulting from the quarterly audits) indicates the QC procedures are inadequate or that the CEMS in incapable of providing quality data. Therefore, whenever excessive inaccuracies occur for [time period], the vessel owner or operator should revise the QC procedures or modify or replace the CEMS.

　

　

9.9.1　RATA RA calculation. Follow the equations described in paragraph 8, performance specification test procedure, of Section 4, to calculate the RA for the RATA. The RATA should be calculated in units of the applicable emission standard.

　

9.9.2　RAA accuracy calculation. Use Equation 1-1 to calculate the accuracy for the RAA. The RAA should be calculated in units of the applicable emission standard.

　

9.9.3　CGA accuracy calculation. Use Equation 1-1 to calculate the accuracy for the CGA, which is calculated in units of the appropriate concentration. Each component of the CEMS should meet the acceptable accuracy requirement.

　

Equation 1-1:

　

A=(Cm-Ca)/Ca x 100

　

	Where:	A=	Accuracy of the CEMS, per cent
		Cm=	Average CEMS response during audit in units of applicable standard or appropriate concentration
		Ca=	Average audit value (CGA certified value or three-run average for RAA) in units of applicable standard or appropriate concentration