3.3 "Operating mode": the recording of changes is only done for steady state engine operation, as the NOx limits defined in the NOx Technical Code are applicable to steady state operation only. Although mentioned in paragraph 2.4.5 of the NOx Technical Code, it is suggested by Euromot not to consider transitional operation for two reasons:
─ transient operation during a restricted time compared to steady state will not contribute to the overall NOx load of the environment,
─ NOx monitoring during transient operation may not only require a special measuring device but also a skilled operator of the equipment. Ship operators will not have such qualifications on board and therefore those recordings may lead to doubtful and misleading results.
3.4 "Recording equipment": it must be very clear that not a measurement device is required but a monitoring device to observe changes of NOx emissions compared to the values on which the certificate is based on.
The operating of a monitoring and recording device under the personnel conditions of ship operation needs highest consideration.
The recording may be done by various means from which the most practical may be selected:
─ on a strip-chart;
─ on magnetic tape;
─ on a table (protocol) filled in and signed by the person responsible for the monitoring.
4 Major parameters to be observed
It has to be assured that the results of any monitoring device can be easily and conclusively related to the initial measurements. This may require:
─ the provision for conversion factors for ambient conditions, mainly air quality and ambient temperature;
─ the documentation of the fuel used by means of the bunker delivery note;
─ an analysis of the fuel used.
Finally, the additional costs (engine, capital and operation) must be considered.
Action requested of tbe Sub-Committee
5 The Sub-Committee is invited to consider the information provided and take action as deemed appropriate.
