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Environmental Management System EMS 05-02 Soot and Soot Water Management |
Doc No.: EMS-05-02 Revision: 0 Date: 15Apr 2023 Issued by: DPA Approved by: MD |
The following key issues and concerns are being addressed in this procedure:
1) Soot Emission from Various Equipment’s. 2) Categorization & Management of Soot and Controls. 3) Reporting Requirements on such discharges. 4) Routines recommended to be followed 5) Measures during IG/ IGG operations in port Limits.In view of several Port-state authorities tightening on and increasing scrutiny on emissions from Funnel as well as scrubber discharges, soot management has become an increasing responsibility as well as concern. This alert aims to streamline on unified understanding wrt Soot, its management onboard and align reporting protocols when such inadvertent discharges of soot is experienced in Port waters.
Depending on vessel types, Soot is normally generated during vessel operations in one or all the following scenarios:
• Exhaust gas Economizer/ Aux Boiler/ Composite Boilers: Release through uptake or wash water • Scrubbers Wash-water: EGCS systems • Inert gas operations from Boiler • Inert Gas generators
1.SOOT EMISSION – POSSIBLE SOURCES
Depending on vessel types, Soot is normally generated during vessel operations in one or all the following scenarios:
• Exhaust gas economizer & Aux Boilers/ Composite Boilers: Release through uptake or wash water • Scrubbers Wash-water: EGCS systems • Inert gas operations from Boiler: Release of soot from funnel and/ or scrubber discharge • Inert Gas generators: Release of soot from funnel and/or scrubber discharge • Incinerators: Soot emission from Funnel (Ash and clinkers) from incinerators to be considered as operational wastes and therefore are included as garbage • Other scenarios of soot release from Exhaust uptakes of ME/DG due to malfunction of combustion components
2.SOOT CATEGORIZATION AND SOOT MANAGEMENT
With present interpretation in MARPOL, soot can be best categorized as garbage basis present industry interpretation. Various soot carry over and its discharges are best defined as below:
Soot release/ discharge possibility with Aux Boiler/Economizer Washdown water:
This economizer wash water or Aux boiler wash water is regarded as "other similar discharges" essential to the operation of a ship, and not as "operational waste" as outlined in Annex V (Ref amendments to the 2012 Guidelines - MARPOL Annex V (resolution MEPC.219-63 /Annex 24 Sec 1.7.3). Such overboard discharges of EGE wash water should also be prohibited for All Flag vessels:
- Soot is separated from wash water by passing through a strainer prior to entering the soot collection tank. The collected soot is landed to Port reception and recorded as “operational waste” category F in the GRB.
- The collected water in the Soot tank should be allowed to rest, and any oil-like traces should be surface skimmed and drained to a sludge tank (any of the 3.1 Listed tanks). Ensure all oil or oily particles are separated and transferred to the IOPP 3.1 listed tank.
- The EGE wash water tank/Soot tank manhole must be seal tagged. The overboard valve for its discharge or suction to the eductor system must be locked and seal tagged at all times.
- In cases when the vessel is in territorial waters, such wash water contents must be stored onboard and can be transferred to the IOPP 3.1 listed tank for eventual evaporation. Such transfer and evaporation must be recorded in the ORB in line with MEPC.1/Circ.736/Rev.2.
| Note: In no circumstances must the EGE wash water be led to the Bilge tank (or Clean Drain tank), as this would contaminate the Bilge tank and interfere with 15ppm OCM operation. If such a design piping exists, the Master/CE must approach the Tech Superintendent and propose modifications to change the draining of EGE wash water to the 3.1 Listed tank. |
Soot release/ discharge possibility during EGCS malfunction:
The wash water discharge from scrubber of EGCS operation is regulated and monitored by various instrumentation & controls inbuilt in the system and permitted as per Port state regulations prevailing on Open Loop/ Closed loop designs.
However, in cases of malfunction of the EGCS, a possibility does exist for soot carry over leading to discoloration of port waters. In such scenarios, Master must stop operations, investigate, inform office and Port state promptly. Recording must be done in the EGCS record book for such malfunctions and in Engine/ Deck Logbook under office guidance.
| Note: In no circumstances must the EGE wash water be led to the Bilge tank (or Clean Drain tank), as this would contaminate the Bilge tank and interfere with 15ppm OCM operation. If such a design piping exists, the Master/CE must approach the Tech Superintendent and propose modifications to change the draining of EGE wash water to the 3.1 Listed tank. |
Soot Release/ Discharge Possibility from Inert gas operations from Aux Boiler:
Inert gas operations from Aux Boiler have high possibility of soot release through IG scrubber wash water in the event of combustion components malfunction and imbalance of Air/Fuel ratio. Normally O2 levels indicate Inert gas quality and any reading of O2 below 1.5 - 2% should be promptly investigated and corrected to avoid soot carryover in scrubber discharge.
In such scenarios of accidental soot carry over or discharge to port waters by scrubber discharge or dry soot from funnel, Master must stop operations, investigate, inform Office and Port state. Entry in Logbooks (deck or engine) will be advised from office. The dry soot collected from port waters/ jetty will be collected, landed and recorded (in GRB) as “garbage – Category F Operational wastes” while the soot discharged through scrubber water will be recorded in Engine Logbook (under office guidance).
| Note:Soot discharge in scrubber wash water and/ or dry soot release from funnel into water/ jetty is prohibited and hence such accidental discharges must be reported to Port and office. |
Soot release/ discharge possibility from Inert Gas Generator Operations:
IGG is normally operated on LSMGO. Despite LSMGO operations, Inert gas generator operations have high possibility of soot release through scrubber wash water in the event of Combustion components malfunction which leads to imbalance of Air/Fuel ratio. Normally O2 levels of 4%-5% indicate satisfactory Inert gas quality. Any reading of O2 below 1.5- 2% should be promptly investigated and corrected, else there is likelihood of soot carryover in scrubber discharge. Smoke emission from funnel also must be monitored as they are first indicator of falling O2 levels and likelihood of soot in scrubber discharge
In such scenarios of accidental soot carry over or discharge to port waters by scrubber discharge or dry soot from funnel, Master must stop operations, investigate, inform Office and Port state. Entry in Logbooks (deck or engine) as necessary to be confirmed with office. The dry soot collected from port waters/ jetty will be collected, landed and recorded (in GRB) as “garbage – Category F Operational wastes” while the accidental soot discharged through scrubber water will be recorded in Engine Logbook (under office guidance).
Note: Soot discharge in scrubber wash water and/ or dry soot release in water/ jetty is prohibited and hence such accidental discharges must be reported to Port and office.
| Ps Note: Under no circumstances must the EGE economizer/ Boiler wash water OR IGS Scrubber water OR EGCS scrubber was water be ever led to any of the IOPP 3.3 listed Bilge Holding tank as this would contaminate the tank as well as interfere with 15ppm OCM operation. If such a design piping exist, Master/CE must approach VM and propose modification for draining of wash water to 3.1 Listed tank. |
3.ACCIDENTAL SOOT RELEASE: REPORTING REQUIREMENTS
All Vessels must seek guidance from office and report to office as well as Port state in following circumstances of soot discharge into Port territorial waters or Jetty:
- Exhaust gas economizer & Boilers: Soot Release through funnel uptake.
- EGCS systems: Soot release through EGCS system Scrubbers Wash-water:
- Inert gas operations Aux Boiler or IGG system: Release of soot from funnel and/ or scrubber discharge into port waters due to malfunction of Combustion control / O2 analyzer etc.
- Any Other scenarios of soot release into Port waters and/ or Jetty from Exhaust uptakes of ME/DG due to malfunction of combustion components.
| Note: Soot discharge through scrubber wash water and/ or dry soot emitted from funnel onto the jetty or port waters, is strictly prohibited. Any accidental soot discharge into Port waters must be investigated as well as immediately reported to office and Port state. Also to be noted is that due to malfunction of combustion components of Boiler/ IGG, there is high likelihood of the scrubber wash water having entrained soot as well traces of unburnt fuel / oily pollutants which may potentially leave a sheen on the sea’s surface. |
4.IMPORTANT CHECKS/ PMS/ MAINTENANCES FOR IGG PLANTS
The Inert gas plants such a Boiler or dedicated Inert gas generator should be duly maintained as per Makers recommended maintenance schedule and as incorporated in PMS. Following routines are normally included as a part of maintenance for both Inert gas generators as well as Aux Boilers, but not limited to:
- Fuel Automation system: • The PLC programming check as per makers defined intervals. This will be done by Makers SE attendances • Fuel automatic control valve and Pressure regulating valve: Checks and renewals as per makers • PLC battery renewals as defined by makers routine • System software upgrade for latest version- Requires Makers service attendances • Air Fuel ratio checks and calibrations for varying loads
- Combustion system: • Burners routine checks and overhauls. • Fuel filters periodic cleaning and fuel temperature maintained as per makers instructions. • Regular and optimized soot blowing at sea will reduce soot build up especially for Aux Boilers and Economizers. • IGG system water spray checks and checks for any leakages of water jackets.
- IGG and IG scrubbers & Deck Seal: • Scrubber should be inspected, and demister cleaned/checked regularly. • Sea water nozzles/spray to ensure enough water flow is there for washing of flue gas. • Deck seals to be checked as per AMOS and cleaned to ensure no soot or deposits.
- IG blowers: • IG Blowers to be water washed/cleaned after every use. • Motor and Blowers to be balanced during dry docking or as per makers recommendation.
- Instrumentation and Controls • O2 analyzer and control system to be serviced by shore/maker service tech as recommended by system maker and in PMS. • O2 analyzer to be calibrated prior to every use. • Uptake valves to be maintained and recorded. • IG vent valves to be checked and maintained. • All IG system alarms to be checked and recorded as per PMS. • Various pressure-temperature switches/transmitters/sensors should be checked/calibrated every docking and ensured functional prior to and during operation. • All gauges Temp-Pressure must be confirmed operational prior to and during IG operations.
5.ADDITIONAL MEASURES TO BE ADAPTED WHEN INERT GAS IN OPERATION- BOILER OR IGG
During inert gas operations, following measures must be additionally implemented over and above existing checks (OTM 7.10, OTM-7.11, E75), inspections and watchkeeping:
- O2 content must be checked periodically and any drop below 2-2.5% must be investigated and informed to CE.
- Any fluctuations in O2 levels and Fuel pressure must be informed to CE.
- Any instability in the flame of IGG/Boiler must be reported immediately to CE.
- Deck watch must be periodically checking ship side for scrubber discharge water discoloration. Any abnormality must be immediately reported to duty officer who will inform Master and CE.
- Deck watch must be periodically checking the Funnel smoke conditions and black smoke must be reported to duty officer, ECR, and CE immediately.
- Recording of such accidental discharges/scenarios to be done with office advice.
- Photos as possible in line with safety/shore permission (as applicable) to be taken for such abnormality and office informed.
- Several start/stops of IGG or IG from Boiler may lead to Air/Fuel ratio imbalance and cause lowering of oxygen levels & soot release. Such scenarios to be supplemented with close monitoring, watch, and office informed on concerns.
- Soot blowers which have feature of auto Blowing, should be kept in Manual and shut before entering territorial waters.
6.VERIFICATION ONBOARD BY VESSELS
- Master / CE to verify on the Inert gas systems onboard and ensure PMS routines match the Makers recommendations.
- If PMS does not exist, then Master/CE to propose new PMS to the shore/Tech Support team.
- All vessels with IGG or Boiler combustion system combustion controls by a PLC, to have battery renewed as per Maker’s schedule. Additionally, shore service/attendance by Makers must be planned for IGG automation every 2.5 yearly docking or earlier as recommended by makers.
- Master/CE to liaise with FG for min spares safe keep onboard as/if needed & jointly identified.
- Address any query pertaining to this compliance to HSSEQ Dept.