Temrs regarding time of the replacement or addition & identical replacement engine
During MEPC.65, IMO published two Unified Interpretations pertaining to Regulation 13 Nitrogen Oxides (NOx) of MARPOL ANNEX VI.
The first of these, UI MPC 98, describes how to interpret the term “time of the replacement or addition“, used to determine the applicable Tier level, when applied to an engine addition or non-identical engine replacement. The second Unified Interpretation, UI MPC 103, pertains to the interpretation of the term “identical replacement engine“.
The term time of the replacement or addition of the engine in regulation 13.2.2 of MARPOL Annex VI is to be taken as:
Tier II compliant engines installed as non-identical replacements or additional engines on board vessels trading in an ECA where the time of the replacement is prior to 1 January 2016 according to either 1.) or 2.) need to be fitted and tested for their intended purpose before 1 July 2016. If they are not, compliance with Tier III is required.
If the engine is delivered in accordance with either .1) or .2) prior to 1 January 2016 but not tested before 1 July 2016 due to unforeseen circumstances beyond the control of the shipowner, then the provisions of unforeseen delay in delivery may be considered by the Administration in a manner similar to that stated in MARPOL Annex I UI4.
The second Unified Interpretation, UI MPC 103, pertains to the interpretation of the term identical replacement engine. In the context of MARPOL Annex VI Regulation 13, a replacement engine is identical to the engine it replaces* if the following characteristics are the same:
for engines without EIAPP certification, the engine has thesame NOx critical components and settings**; or
for engines with EIAPP certification, the engine belongs tothe same Engine Group/Engine Family.
|* In those instances where the replaced engine will not be available for direct comparison with the replacement engine when the Supplement to the IAPP Certificate reflecting the engine change is updated, it is to be ensured that the necessary records in respect of the replaced engine are available so that it can be confirmed that the replacement engine represents an identical engine.|
** For engines without EIAPP Certification, there will not be the defining NOX critical component markings or setting values usually given in the approved Technical File. Consequently, in these instances, the assessment of … same NOX critical components and settings … shall be established on the basis that the following components and settings are the same:
Fuel pump model and injection timing
Injection nozzle model
Configuration and, if applicable, turbocharger model and auxiliary blower specification
Cooling medium (seawater/freshwater)