ACS Guidelines No.

ACS Guideline for SOX Emissions Compliance Plan

(SECP)

2017

Association of Asian Classification Societies

www.asiancs.org
 ACS Guideline for SOX Emissions Compliance Plan (SECP)

FOREWORD
SOx in the shipboard exhaust gas is the pollutant generated after the combustion of
sulphur in the fuel oil. It is very difficult to achieve the objective of controlling SOx
emission by self-improvement of fuel oil combustion units (such as diesel engines,
boilers, etc.). Control is only possible through pre-treatment of fuel oils,
after-treatment of exhaust gas or alternative fuels, i.e.:
- pre-treatment of fuel oils: using specialized process to desulfurize fuel oil so that
the ship uses low-sulphur oil complying with the requirements;
- after-treatment of exhaust gas: removing SOx in the exhaust gas by installing
exhaust gas treatment unit so as to achieve emission reduction equivalent to that
of using low-sulphur fuel oil;
- alternative fuels: ships use clean fuels such as natural gas; as natural gas is low in
sulphur, SOx emission is low after combustion.

As the number of global emission control areas is ever on the increase, and in
particular since 2020 ships engaged on international voyages can only use fuel oils
with a sulphur content not greater than 0.5%, resulting in supply shortage of
low-sulphur oil and sharp increase in the fuel cost of ship operation, after-treatment of
exhaust gas (namely exhaust gas cleaning systems, EGC systems) or alternative fuels
become the main alternative solution chosen by shipowners and designers.

Exhaust gas cleaning systems are frequently applied post-treatment technology in

marine transportation section. IMO specifically developed the Guidelines for Exhaust
Gas Cleaning Systems, 2009 (resolution MEPC.184(59)) and the latest amendments
was also approved and adopted in 2015 (resolution MEPC.259(68)), these Guidelines
specifies that ships fitted with the EGC system should have an approved SOx
Emissions Compliance Plan (SECP). ACS develops this Guideline with the aim to
assist the shipowners, shipyards, EGC system manufacturers, etc. in preparing the
SECP.

Feedback from the industry on the contents of ACS guidelines are welcomed anytime.
E-mail: technical.office@asiancs.org

DISCLAIMER

The ACS, its member, and their respective officers, employees or agents, individually
and collectively, assume no responsibility and shall not be liable to any person for
any loss, damage or expense caused by reliance on the information, advice and
documents included in this Guideline.

ACS is an association of six Classification Societies headquartered in Asia;

BKI, CCS, IRS, KR, NK and VR.
 ACS GUIDELINE FOR SECP

CONTENTS

Chapter 1 GENERAL

Chapter 2 GENERAL REQUIREMENTS OF SOX EMISSIONS COMPLIANCE PLAN (SECP)

FOR EXHAUST GAS CLEANING SYSTEMS (EGC SYSTEMS)

Chapter 3 SPECIAL REQUIREMENTS OF SOX EMISSIONS COMPLIANCE PLAN (SECP)

FOR EXHAUST GAS CLEANING SYSTEMS (EGC SYSTEMS)
Chapter 1 GENERAL

1.1 Application

1.1.1 The international conventions, relevant regions and countries have laid more and more
requirements on shipboard SOx emission control. For the general requirements of conventions and
relevant regional/national regulations for the limit of the sulphur content of fuel oils used by ships,
see the following Table 1.

Table 1: List of Requirements for the Limit of Sulphur Content of Fuel Oils
Sulphur content in
Source Date Applicable Area
fuel (%, m/m)
≤3.50 From 2012.01.01
Revised MARPOL Outside SOx ECAs
≤0.50 From 2020.01.01
Annex VI
≤0.10 From 2015.01.01 Within SOx ECAs
EU Directive:
≤0.10 From 2010.01.01 EU ports
2016/802
California Air ≤0.10 (only MGO
Resource Board and MDO are From 2014.01.01 California Waters
(CARB Regulation) accepted)
Hong Kong Air
Pollution Control ≤0.50 From 2015.07.01 Hong Kong ports
Regulation
Berth at core ports
≤0.50 From 2016.04.01 within DECAs of the
Yangtze River Delta
Berth at Shenzhen
China Domestic
≤0.50 From 2016.10.01 port within DECAs of
Emission Control
the Pearl River Delta
Areas
Berth at core ports
Implementation ≤0.50 2017.01.01 - 2017.12.31
within DECAs
Scheme
Berth at all ports
≤0.50 2018.01.01 - 2018.12.31
within DECAs
≤0.50 2019.01.01 - 2019.12.31 Area within DECAs
≤0.10 From 2020.01.01 Area within DECAs

1.1.2 According to the resolution MEPC.259(68), "For ships which are to use an exhaust gas
cleaning system in part or in total in order to comply with regulations 14.1 and/or 14.4 of
MARPOL Annex VI, there should be an approved SOx Emissions Compliance Plan (SECP)",
therefore ship should have such an approved SECP when it is decided to install the EGC system.

1.2 Terminology
1.2.1 The terms used in this Guideline are defined as follows:
(1) "Scheme A" means a survey and certification method to demonstrate the emissions
compliance of EGC systems by testing and parameter checks.
(2) "Scheme B" means a survey method to demonstrate the compliance of emissions from EGC
systems by continuous monitoring of SOx emissions in exhaust gas.
(3) "Fuel Oil Combustion Unit" means any engine, boiler, gas turbine, or other fuel oil fired
equipment, excluding shipboard incinerators.
(4) "EGC Record Book" means a record of the EGC unit in-service operating parameters,
component adjustments, maintenance and service records as appropriate.

1.2.2 The abbreviations used in this Guideline are summarized as follows:

(1) EGC: Exhaust Gas Cleaning.
(2) ETM-A: EGC System-Technical Manual for Scheme A.
(3) ETM-B: EGC System-Technical Manual for Scheme B.
(4) FOCU(s): Fuel Oil Combustion Unit(s).
(5) MCR: Maximum Continuous Rating.
(6) OMM: Onboard Monitoring Manual.
(7) SECP: SOx Emissions Compliance Plan.
Chapter 2 GENERAL REQUIREMENTS OF SOx EMISSIONS

COMPLIANCE PLAN (SECP) FOR EXHAUST GAS CLEANING

SYSTEMS (EGC SYSTEMS)

2.1 General requirements

2.1.1 SOx Emissions Compliance Plan (SECP) should be submitted for approval no matter
whether the Scheme A or Scheme B is selected where a ship is intended to be fitted with the EGC
system certified in accordance with the requirements of the resolution MEPC.259(68).

2.1.2 The SECP is a plan to specify how the ship complies with the relevant requirements
stipulated by the resolution MEPC.259(68). Therefore, the SECP should cover all EGC systems
installed on the ship rather than development of individual SECP for each EGC system. The SECP
should list each item of fuel oil combustion equipment which is to meet the requirements for
operating in accordance with the requirements of regulations 14.1 and/or 14.4 of MARPOL Annex
VI at least.

2.1.3 There may be some equipment such as small engines and boilers to which the fitting of EGC
units would not be practical, particularly where such equipment is located in a position remote
from the main machinery spaces. All such fuel oil combustion units should be listed in the SECP
and for these fuel oil combustion units which are not to be fitted with EGC units, it should state in
the SECP the compliance means and this may be achieved by using the fuel oil as required in the
related regulations/directive, for example, 14.1 and/or 14.4 of MARPOL Annex VI.

2.1.4 The SECP should indicate that each EGC system is to be able to effectively treat the exhaust
gas under the maximum continuous rating (MCR) of the FOCU(s) connected with the system. For
diesel engines, MCR is the rated power; for boilers, MCR is the rated evaporation capacity or
rated thermal power.

2.1.5 The SECP may explain how the exhaust back pressure is to remain within the limits stated
by FOCU(s) manufacturers under all operating conditions after installation of the EGC system.

2.1.6 Where the exhaust gas system is installed with other post-treatment device (such as SCR) in
addition to the EGC system, the compatibility of those post-treatment systems may be considered
and more details may be provided in the SECP.

2.1.7 The SECP may describe how to deal with the situation in the event the EGC system is not in
operation due to the equipment failure or emergency shut-down, and the consequent emergency
preparedness/response activities, provided that this issue is not described either in the ETM-A or
in the ETM-B.
2.1.8 If the requirements contained in 2.1.2 - 2.1.6 have been specified in other document, such as
but not limit to EGC System-Technical Manual (either ETM-A or ETM-B), EGC Record Book or
Engine-Room logger system, data recording system or Onboard Monitoring Manual (OMM), as
an alternative, the SECP could contain the information by referring to the document.

2.1.9 The approved SECP should be kept onboard the ship and if there is any change (either for
the EGC system or for the FOCU(s)) which affects the emissions performance, the SECP should
be updated to reflect it and re-submitted for approval.
Chapter 3 SPECIAL REQUIREMENTS OF SOx EMISSIONS

COMPLIANCE PLAN (SECP) FOR EXHAUST GAS CLEANING

SYSTEMS (EGC SYSTEMS)

3.1 Special requirements for Scheme A

3.1.1 The SECP should present how continuous monitoring data will demonstrate that the
following minimum parameters are maintained within the manufacturer's recommended
specifications at a rate which is not to be less than 0.0035 Hz. The relevant information on the
parameters could refer to ETM-A, not directly indicating in SECP.
(1) Washwater pressure and flow rate at the EGC unit's inlet connection.
(2) Exhaust gas pressure before and pressure drop across the EGC unit.
(3) Fuel oil combustion equipment load.
(4) Exhaust gas temperature before and after the EGC unit.
(5) Consuming chemicals if it is documented in ETM-A at a known rate.

3.1.2 The continuous exhaust gas emissions monitoring mentioned in 3.2.3 may be demonstrated
using daily exhaust gas emission recordings and could be recorded in the EGC Record Book / data
recording system rather than in the SECP.

3.2 Special requirements for Scheme B

3.2.1 The SECP should set up the required emission value and may be demonstrated in the SECP
that the emissions from FOCU(s) fitted with the in-operation EGC system will, result in the
required emission value or below at any load point, including during transient operation. The
relevant information on the required emission value could refer to ETM-B, not directly indicating
in SECP.

3.2.2 The minimum parameters mentioned in 3.1.1 may be demonstrated in the SECP and would
be demonstrated using daily recordings of key parameters, as an alternative it could be recorded in
the EGC Record Book / data recording system.

3.2.3 The SECP should present how continuous exhaust gas emissions monitoring will
demonstrate that the ship total SO2 (ppm)/CO2 (%) ratio is not to exceed the applicable limits
prescribed in Table 2: Correspondence between fuel oil sulfur limits and SO2/CO2 ratios.

Table 2: Correspondence between fuel oil sulfur limits and SO2/CO2 ratios
SO2 (ppm)/CO2 (% v/v) Fuel oil sulfur limits (% m/m) Remarks
151.7 3.50 MARPOL Annex VI Reg. 14.1.2
65.0 1.50 MARPOL Annex VI Reg. 14.4.1
43.3 1.00 MARPOL Annex VI Reg. 14.4.2
SO2 (ppm)/CO2 (% v/v) Fuel oil sulfur limits (% m/m) Remarks
21.7 0.50 MARPOL Annex VI Reg. 14.1.3
4.3 0.10 MARPOL Annex VI Reg. 14.4.3