TIER 3 SYSTEM MALFUNCTION

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What is your experience with Tier 3 (EGR or SCR) systems malfunctions, within NECA?

There is this guidance for scrubber systems ,MEPC.1/Circ.883 , that “allows” for 1 hour malfunctions, full text below:
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1. Any malfunction that lasts for more than one hour or in case of repetitive malfunctions, in pursuant to regulation 5.6 of Annex VI of the MARPOL Convention, it is imperative that such a situation is reported to the flag Administration of the vessel, to the vessel’s Class and to the relevant port State control competent authority, along with an explanation of the steps the ship operator is taking to address the failure.
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Is it a big leap of logic to apply this “allowance” also to EGR systems?

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Spyros,
In principle, yes, this paragraph can be logically applied to EGR systems. EGR systems are considered Exhaust Gas Cleaning Systems. However, this is not clearly defined by the IMO or the Class Societies yet. It is a grey zone because theses systems are governed by the NOx code as well.
In case of EGR malfunction in a NECA area, in order to comply with the TIer III regulations, you may ask the vessel to reduce the Main Engine load. The EGR is disengaged at loads below 12% MCR. Check the NOx file of the Main Engine and you should find a paragraph similar to the below. However, please note that the low load limit for continuous operation set by MAN ES is 10% MCR.

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