Last week on our FAQs article we highlighted the ENVIRO Notations that shippers have to follow in order to comply with environmental regulations. However, this isn’t the sole one, there are others in the fray. So, here we are giving you detailed information on Low Emission Vessel or LEV Notations as published by an ABS guideline.
Let’s take a look.
Scope of this notation
The optional notation LEV recognizes that the specified internal combustion engines installed on a vessel meet stricter gaseous and particulate pollutant limits than regulated by MARPOL Annex VI. The LEV notation recognizes that engine emissions meet the corresponding levels for engine size, power and application regulated by other regional, national or local regulatory instruments, for example EU for equivalent marine, heavy duty or non-road mobile machinery applications.
Typically, these regulatory instruments regulate NOx emissions, as does MARPOL Annex VI Regulation 13, but in addition set limits for CO, HC, PM and PN.
The benchmark emissions limits for the ABS LEV notation are EU Tier V, for example EU Regulation 2016/1628.
Assignment of the optional LEV notation is strictly voluntary and does not confer compliance, certification, Type Approval or any other form of formal documentation of regulatory compliance with other regulatory instruments.
Vessels installed with engines in compliance with the requirements of Section 4 of this Guide may be assigned the class notation LEV, Low Emissions Vessel.
Internal combustion engines which are solely intended to use for emergencies or installed in the lifeboat of a vessel are not required to comply with these requirements.
Plans and Documentation
The following plans and documentation are required to be submitted, as applicable, to receive the Low Emissions Vessel, LEV notation:
i) The list of engines installed onboard including their purpose or use, emissions test cycle (e.g. E3, E2, D2, C1) and serial numbers.
ii) For those engines that have already been certified as meeting other regional, national or local exhaust emissions regulatory instruments, all documentation associated with that certification or type approval, e.g. certification, technical details, test plans, emissions test reports, third party endorsements, etc.
Note: Those engines will also need to be verified as meeting the requirements of 4-2-1 of the Marine Vessel Rules before being eligible to be installed on ABS Classed vessels.
iii) Technical details of engine type / model, this may include, but is not limited to, kW/cylinder, BMEP, compression ratio, cylinder configuration together with additional information critical to the engine exhaust emissions including, but not limited to, fuel injection system including injection timing arrangements, combustion chamber details, turbocharging and charge air cooling arrangements, any specific engine or emission control features, and in particular for engines designed for lower emissions under this LEV framework, details of exhaust aftertreatment systems such as SCR systems or Diesel Particulate Filters (DPF). This information may be summarized in a LEV technical file where not already captured by the Annex VI and NOx Technical Code NOx technical file or the documentation requirements of other regulatory instruments.
iv) Proposed categorization of the engine family or engine group, including adjustable features, applicable fuel specifications, means for spare part supply, etc.
v) Testbed and emissions measurements procedures and relevant standards, such as ISO 8178-1
vi) Emissions test report as witnessed and verified by an independent third party acceptable to the Bureau, for example a Recognized Organization authorized by the flag Administration or regulatory authority.
vii) A document containing information for on-board verification of the emission components, settings, replacement parts and controls to verify continual compliance with the LEV emission limits.
viii) Operation and maintenance manuals for the engine and, in particular, any aftertreatment systems such as SCR or DPF units required for achieving LEV emission levels.
Engine Exhaust Gas Emissions
Emission Limits
The benchmark emissions limits for the ABS LEV notation are EU Tier V, as refrenced in EU Regulation 2016/1628 and tabulated below in Table 1 for inland waterway propulsion (IWP) and inland waterway auxiliary (IWA) engines with emissions limits.
Engine Emission Tests
Engine emissions tests are to be undertaken in accordance with the requirements of the specified regulatory instrument referenced by the application for ABS LEV notation.
ABS will also consider assignment of the LEV notation(s) based on testing undertaken in accordance with Annex VI and the NOx Technical Code (NTC) Chapter 5 and ISO 8178. Where the request for notation includes recognition of the emissions levels of PM and/or PN (which are not regulated pollutants within Annex VI and the NTC), then this testing is to be undertaken at the same time as the gaseous emissions
testing and is to be undertaken in accordance with ISO 8178-1, “Reciprocating internal combustion engine – Exhaust emission measurement – Part 1: Testbed measurement systems of gaseous and particulate emissions”.
Engine Emissions Verification
The engine exhaust emissions test report, together with the documentation outlined under 4/3 of this Guide, will be reviewed by the designated ABS technical office for verification of the gaseous and particulate exhaust emissions and confirmation of acceptability for assignment of the LEV notation.
A copy of the approval letter, together with the LEV specific documentation referenced under 4/3 of this guide (technical file, onboard verification document and operation and maintenance manuals, as applicable) required for on-board verification of continual compliance with the LEV emission limits are to be retained onboard for verification during the initial, annual, intermediate and renewal MARPOL Surveys.
Notations and Recognition
The optional LEV notation will be assigned upon verification that the specified installed engines meet the requirements of Section 4 of this Guide.
Upon satisfactory review of the submitted plans and documentation, together with verification of the installation onboard to the Surveyor’s satisfaction, the vessel will be eligible for assignment of the LEV notation, A record comment will be issued indicating descriptive letters recognizing the specified regulatory instrument emission limits that the engine has been recognized as meeting, and the associated gaseous or particulate pollutant.
Some examples are listed below:
● LEV (Main Engine EU Stage V, IWP, NOx, CO, HC)
● LEV (Aux Engine EU Stage V, IWA, NOx, CO, HC, PM, PN)
The LEV notation recognizes that the specified internal combustion engines installed on a vessel meet stricter gaseous and particulate pollutant limits than regulated by MARPOL Annex VI. However, assignment of the optional LEV notation is strictly voluntary and does not confer compliance, certification, Type Approval or any other form of formal documentation of regulatory compliance with other regulatory instruments.
Engines using SCR or EGR equipment to meet the LEV NOx limits, are to comply with the applicable requirements of the ABS Guide for Exhaust Emission Abatement, for assignment of the LEV notation.
Surveys
As applicable, all annual, intermediate and renewal or periodical surveys for MARPOL Annex VI Regulation 13 are to be satisfactorily completed, as well as completion of the periodical survey requirements of machinery, as specified in Chapters 6 and 8, and survey requirements of Sections 7-9-7 and 7-9-13 of the ABS Rules for Survey After Construction (Part 7). Additional verification required by the LEV documentation will be completed at the initial survey and the aforementioned surveys. At each survey, the attending Surveyor is to verify that the following are maintained onboard:
i) Certification and documentation as outlined in 4/3 and 4/5.3 of this Guide.
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Source: ABS
