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Tuesday, November 13, 2018

Greek technical managers speak out on abatement technology

This open letter has been circulated by the Piraeus-based MARTECMA, the Marine Technical Managers' Association, which represents 80 Greece-based major ship management and ship operating companies as well as six major technical consulting companies, in order to counterbalance a number of press articles which imply that the majority of technical people in Greece are convinced of the viability of retrofitting scrubbers or other abatement technologies as they are presently available in the market.



We take the opportunity to circulate this Open Letter because we feel that a recent rash of Articles that have appeared in the Newspapers and Magazines insinuate an inaccurate position of the Shipping Technical Community in Greece.


As you are probably aware, MARTECMA is the Association of the Technical Managers of 80 of the major ship management and operating companies in Greece, (as well as six of the major Technical consulting offices as associate members).


During our various meetings in the recent past we have been called-on to discuss the various options and problems facing the shipping industry in trying to deal with the upcoming legislations on gas emissions.


Our discussions have centered solely on techno-economic aspects of the installation and operation of equipment and/or the effects of different solutions on the safe and environmentally friendly operation of ships.


We, as association, have tried to be open minded and non-committal about publicly supporting anyone of the options being discussed.


However, there is a general feeling that the consensus of technical opinion of the Greek shipping society related to air pollution prevention has been lately misrepresented.


We would like to clarify the following points, always bearing in mind that we are confining our positions to the extent of our expertise which is the construction, conversion, repair, and technical operation of vessels.


a)     None of the options that are presently being discussed can be considered as being effective in simultaneously dealing with the SOx NOx, Particulate Matter, and CO2 emission problems.

All above problems are very closely intertwined and dealing with one could grossly affect one or all the others in an adverse way. We are not at all sure that enough unbiased research has been carried out to properly evaluate the side effects of any of the abatement systems. We also sense, that various interests (parties), especially those outside of the shipping community and control of IMO, are submitting data in a format which is solely for their interest and peace of mind. This makes a realistic global evaluation of net effects on pollution of existing options very difficult.


b)     In MARTECMA there exists a vast amount of expertise on repair, conversion, up-grading, and further maintenance and operation of all types of vessels. Based on this expertise, we find the studies on the possibility of retrofitting scrubbers on existing Tankers, Bulk Carriers, Containerships, to be optimistic if not unrealistic.


c) Most of the publicized studies, and numbers, being voiced are based on the installation of one large scrubber for main engine only.

However, if one truly wants to deal with all sources of ship gas emissions - both at sea and in port - they will have to install scrubbers for each of the boilers and diesel generators together with their dedicated or shared pumps water pipes exhaust pipes etc.

This means that all such studies should be done with the time, space, and cost consideration for installation of 4 to 6 scrubber that would in fact be required for each of the above types of vessels.


d) We are further worried by the sizing assumptions taken in many of these studies because such treatment systems greatly depend on the ions and salts which are readily available in sea water.


These processes would be very inefficient (if not totally ineffective) when sailing in fresh or brackish waters which are predominant in the majority of the world's ports where the pollution problems are most acute.

Some of the Makers of abatement equipment claim that their equipment deals with the reduced efficiency by greatly increasing the volume of fresh or brackish water used to treat the exhaust gases.

If this is the case, we are not at all sure that the sizing of pumps, pipes and the scrubber themselves used in the studies, have accounted for the huge increases of water volume required. This would greatly aggravate the already extreme problem of the space, volume, and even consumption factors.


e) Commercial vessels built in last 20 years, have been optimized in terms of the spaces allotted for machinery and accommodation areas. Thus, required installations of even the one large main engine scrubber are very hard to locate. If in fact one realizes that and additional 3 to 5 various size scrubbers with their accompanied machinery and piping must be installed, the problems become phenomenal.


f)   The installation problems are further aggravated by the fact that in the medium to smaller size Tankers and the majority of Bulk Carriers the engine, boiler and electrical generator exhaust pipes come up through a space in the middle of the accommodation house. Any efforts to expand the exhaust ducts on funnels would require the dismantling and modification of the accommodation decks them-selves. In the larger vessels, which might have separate exhaust houses (engine casings) and the possibilities of adding decks or other expansions would still require major reinforcing if not cropping out and renewing of the deck houses themselves located below.


h) Unlike the ferry boats and passenger vessels, who have multiple but smaller engines (presently used in experiments with smaller size scrubbers), on commercial vessels such as Tankers, Bulk Carriers and Containerships, such equipment cannot be installed in anywhere along the length of the vessels. Rule regulations and explosion hazards limit the installations to aft of the already short accommodation length outside the cargo areas and make such multi storey scrubber towers very difficult to accommodate.


i)              As a final point, one must consider the availability and delivery time for the many tens of thousands of various sized scrubbers that would be needed for the main engines boilers, diesel generators etc., as well as the shipyards' slots for the length of times for (what we hope is now understood to be) the major conversions that would have to be carried out in order to install these scrubbers and their related pumps, pipes, etc.


We are certain that if due consideration is given to the above mentioned practical hurdles, the time required and the cost incurred will prove retrofitting of scrubbers to be non competitive in practical as well as well as ecological terms as a retrofitting option on existing or already ordered vessels.


The only remote possibility for such systems would be at the time of new building, and when the designers could possibly design the vessels around such mandated equipment. However, even in such case, we consider a lot more work would still be required in improving the size, and efficiency of such equipment, as we fear the operating consumptions and maintenance to be required might prove to be counter productive in both fuel consumptions and resulting emissions which might lead to a second round of legislative limitations.


For all of the above reasons, we take objection to the many Media Articles that have insinuated that the majority of Technical people in our area are convinced of viability of retrofitting scrubbers or other abatement technologies as they are presently available in the market, to the contrary we feel that other options should be more seriously considered especially for retrofits on existing or already ordered vessels.


We thank you very much for correcting any misunderstandings that might have been generated and you are free to use our above sincere opinions in your participation in the relevant IMO Committees.


Yours truly,

On behalf of