Fishermen's News - The Advocate for the Commercial Fisherman

Propulsion Systems: Guidance for Newbuilds and Repowers


July 1, 2017

John Deere PowerTech 9.0L Marine Tier 3 engines meet EPA Marine Tier 3 emissions requirements.

Regulations, primarily centered on emissions, are the predominant discussion topic going into a conversation about a propulsion project.

"There are two distinct categories," says Geoff Conrad, Director of Marine for Cummins Sales and Service. "A new vessel project, and an engine replacement project. To navigate those situations, it's fairly confusing. Not so much for the engine manufacturers, because we have to know what's involved, but for the end customer, there's no clear, concise simple rule that applies.

Anything from 805 HP and above is subject to US EPA Tier 4 regulations, but the EPA has staggered the implementation of Tier 4 engines. Larger displacement engines happened first in 2014. The last power band to be regulated is in the 806 HP to 1,300 HP. New vessels requiring power from 806 HP to 1,300 HP need to have started construction and engine orders placed with ample time for engines to be in the US.

While manufacturers have to comply and move from Tier 3 to Tier 4 products, it's a fairly major shift in technology. The EPA doesn't dictate the technology used; only what level of emissions have to be met. Most manufacturers are using after treatment systems, or selective catalytic reduction systems (SCR), which treats the exhaust. "You're treating the exhaust by injecting special fluid into the exhaust stream where a chemical reaction takes place. This process has been in use for the trucking and industrial applications for years, but is relatively new to the marine segments. The system is more costly, and does require maintenance," says Conrad.

Most modern diesels today are electronically-controlled. There is a lot of emissions reduction that happens inside the cylinder during its ignition. "It's amazing how much cleaner the product has become over the last 10 years: improvements on fuel systems, improvements on air handling, improvements on the way the combustion takes place, and the fuel is consumed more. If you can reduce emissions there, what comes out of it after its power has been expended, it's easier to treat because there's less of it," he says.

Operators, Naval Architect firms and shipyards are evaluating the power options, some favoring switching from single propulsion designs to twin engines of less than 805 HP. "There's nothing in the rules that stipulates how many engines you can use or not in that boat. In the old days, a steel-hull dragger operating out of Kodiak may have had one engine at 1,000 HP or 1,200 HP," Conrad explains. "Today, if they were to build a new replacement vessel for that, they probably wouldn't use one engine. They would use two. The reason for that is they want more power, and they'd rather avoid the cost and complexities and maintenance of a Tier 4 system in a part of the world that's pretty demanding and tough to operate in. It's just new technology, and with any new technology, it requires testing, vetting of the applications, and making sure that customers know how to maintain it. It's not maintenance-free. There are things you have to do. Generally speaking, it requires a higher level of understanding and training for those customers and what's required."

When it comes to repowering vessels, doing so is allowed under the EPA rules, which is helping replace non-emissions certified engines that are 15-20 years old. "They're not saying you have to go to Tier 4 when you repower, as they do with new vessels. What they're saying is, put the best one you can in there, or tell us why the best won't work in that application," explains Conrad.

So if engines are taken out of a crabber, for instance, the EPA prefers owners to put the most environmentally-friendly engine in, which could be a Tier 4. "It will cost the vessel owner more money to accomplish the engine repower," says Conrad. "They may not have the space accommodation and would likely have to change their exhaust runs and engine room ventilation, keel cooling space or placement issues, and underwater electronics, so it becomes space constrained and cost-punitive. Then the engine manufacturer will assess with the owner, and they can make a determination if installing that engine will only require light modifications."

The EPA puts the burden on the engine manufacturer to determine with the customer, what course of action to take, and they will audit the engine manufacturers as to compliance. The EPA will also instruct the engine manufacturer to destroy the old engines, and Cummins does that for their customers.

According to Conrad, many customers make the mistake that when the new vessel rules go into effect, they assume for repowers, the same rules will apply. "It's situational, and your engine manufacturer will be able to provide you with options for what they have available. We don't let one of our salespeople make that judgement call," says Conrad. "We have an independent person or persons within the Cummins organization who assesses these requests. We cannot order or release an engine unless we have that sign-off," he says, pointing out that rather than simply filling an engine order as it happened in the past, manufacturers now have to become engine guidance counsellors in order to provide the best advice on engine applications.

Besides the changes around meeting the emissions standards, which are significant, fuel economy can also be improved. "With Cummins you can get a 1-3 percent savings in fuel even though the engine has higher emission standards," Conrad explains. "When you have tougher emissions standards and you can lower fuel consumption, and that's a good thing. Even though fuel is relatively inexpensive today, it changes drastically, and any advantage you can have there is not only good for the environment but your wallet."

Cummins is working to reduce or eliminate the number of disposable filters on its engines. "Not every manufacturer does that," says Conrad. "As part of the marine society rules, there's an increased emphasis on the engine's ability to be properly disposed of in regards to any hard metals or metals that may cause contamination when the engine's disposed of." Conrad says Cummins has a well-established used, rebuilt, certified product replacement engine program. "We do hundreds of them every year, in marine and on the West Coast," he says. "For the fishermen, it's a very good solution because there is generally less cost than for a new engine, they already know it will fit in the same spot, or pretty darn close with a little modification, and we stock these engines all the time. It's a very economical benefit, and the payback is much greater."

Bill Mossey, Vice President for Pacific Power Group says, "The regulatory impact from the perspective of emissions continues to be the primary driver in the business. And that is true for the product lines of MTU and Volvo Penta."

Mossey says in September, the EPA issued a delay in the final implementation because not all engine manufacturers were ready. By this fall, for new construction above 600 kW/805 HP, all vessels will have to be built with Tier 4 engines.

For customers, there is limited selection of Tier 4 engines on the market that meet these regulations, due to different manufacturers launching products on different timetables. Mossey says PPG's earliest releases will be delivered in very early 2018, with a full release of the entire product range in 2019.

He explains there are different standards for different usage of engines. For instance, there is no Tier 4 regulation for recreational engines and the test cycle is different than for commercial engines, which have more stringent requirements. Manufacturers have to test the different engines for commercial usage longer than for leisure usage and for deterioration of emissions, which, in many cases, involves thousands of hours of testing in an emissions lab. Emissions are measured at the beginning, the end, and at different intervals during the test. "You build a rate of deterioration and basically have to prove that based on the deterioration rate, that engine will still emit within the emission limits at the end of the useful life."

Mossey says another dynamic in compliance is the IMO ECA (Emission Control Areas), whose regulations affect engines from 130 kW or 174 HP and above. "When you're in an ECA area, you need to have an IMO Tier 3 engine, which is nearly equivalent to EPA Tier 4. This IMO regulation went into effect in 2016, and is being enforced for craft that sail out of US waters and into international waters," he explains. "The current view is if the engine is manufactured after 2016 on a commercial vessel, they need to be compliant to IMO, and that means they need to have an IMO Tier 3-certified engine. And there are none available in the marketplace under 805 HP that I'm aware of. So we have a growing problem in that most manufacturers don't have any immediate plans to comply with that regulation, and a lot of our customers don't think it's a problem because they don't think they actually sail out of US waters." Mossey says Transport Canada has an exemption in place to allow US vessels to transit through that are not IMO compliant. "I think there is some concern that won't remain in effect for multiple years. That's also an area of concern to the industry."

IMO Tier 3 and Tier 4, from nearly all manufacturers, require exhaust after treatment for compliance, and it has to be provided by the engine manufacturer, and certified. The requirement to be IMO-certified is easier than the EPA because the IMO doesn't have the deterioration testing requirement.

It's tricky for commercial fishing vessel owners to fully understand the requirements, particularly as they keep changing for both new construction and for repowers. "You have to consult with your engine distributor to ensure you're in compliance with the law," adds Mossey. "We all try to be experts within a least the product ranges we're selling so we can properly advise our customers. And the engine distributor carries legal risk with EPA, and so does the owner of a vessel. If they knowingly violate a law, they can be subject to fines. The EPA fine is up to $32,500 per day per incident per engine.

Going back to sailing out of US waters, Mossey says the border entry process can include asking for documentation of emissions compliance to MARPOL Annex VI code, often referred to as the IMO code – a document called an Engine International Air Pollution Prevention Certificate (EIAPP) is required to be issued by the engine manufacturer of the installed engine on the vessel. "The document may be required to gain entry into a foreign country and or back into the USA. If a US-flagged vessel travels to Canada or Mexico, it should have EIAPP documentation as a minimum for the engine, and the owner should also consider carrying the equivalent documents for the vessel," he says.

Volvo Penta D13 Propulsion engine, EPA T3, IMO II, available in power ratings from 400 BHP – 800 BHP and for generator sets from 300 – 380 kWe.

Carl Micu, Manager, Engines and Drivetrain Sales, North and South America for John Deere also weighs in on the state of emissions regulations: "From an emissions standpoint we and other engine manufacturers continue to work with Transport Canada, EPA and the US Coast Guard related to enforcement of IMO MARPOL Annex VI NOx regulations in the Emission Control Areas (ECA) and within Canada," he says. "There has been some communications related to US-flagged vessels transiting in and out of US waters needing to meet the IMO requirements. IMO regulates NOx levels for engines rated at and above 130 kW to a level that requires after treatment. The EPA regulations do not require after treatment for engines below 600 kW. Engine manufacturers are struggling with justification to develop after treatment packages for engines in the 130 kW-600 kW range for those vessels that fall into the definition of needing to meet IMO MARPOL Annex VI requirements."


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