Consulting Engineers Serving the Marine Community

Exhaust Gas Cleaning Systems 

Selection Guide 

Prepared for 

Ship Operations Cooperative Program (SOCP) 

Ellicott City, MD 

File No. 10047.01 

22 February 2011 

Rev. A 
1201 Western Avenue, Suite 200, Seattle, Washington 98101-2921 TEL 206.624.7850 FAX 206.682.9117 www.glosten.com

Consulting Engineers Serving the Marine Community

Prepared for 

Ship Operations Cooperative Program (SOCP) 

Ellicott City, MD 

File No. 10047.01 

22 February 2011 

Rev. A 

 

BY: _____________________________________

Kevin J. Reynolds, PE 

Project Marine Engineer 

___________

CHECKED: _______________________________

Sean A. Caughlan, PE 

Senior Marine Engineer 

___________

APPROVED: ______________________________

Richard S. Strong 

Principal-in-Charge 

___________

Exhaust Gas Cleaning Systems 

Selection Guide 

SIGNED COPY ON 

FILE AT GLOSTEN
Exhaust Gas Cleaning Systems i The Glosten Associates, Inc 

Selection Guide, Revision A File No. 10047.01, 22 February 2011 

Contents

Executive Summary ........................................................................................................................... iii

Section 1 Introduction ................................................................................................................... 1

1.1 Sulfur Limit Requirements ....................................................................................................... 1

1.2 Sulfur Limit Approaches .......................................................................................................... 1

1.3 Issues Addressed by This Guide ............................................................................................... 2

Section 2 Sulfur and Other Emissions Requirements and Guidelines ..................................... 3

2.1 Applicability ............................................................................................................................. 3

2.1.1 International .................................................................................................................... 3

2.1.2 Emissions Control Areas (ECAs) .................................................................................... 4

2.1.3 Federal – United States.................................................................................................... 4

2.1.4 Regional .......................................................................................................................... 5

2.2 NOx Focused Tier Requirements ............................................................................................. 5

2.2.1 IMO Annex VI NOx Details ........................................................................................... 7

2.2.2 EPA Category 1 and 2 Tier Details ................................................................................. 8

2.3 Sulfur Requirements ................................................................................................................. 8

2.3.1 MARPOL Annex VI, 2008 ............................................................................................. 8

2.3.2 EU Ports (Directive 2005/33/EC of the European Parliament and of the Council) ........ 9

2.3.3 California Coastal (California Air Resources Board) ..................................................... 9

2.3.4 US – EPA Category 1 and 2 Engine Vessels .................................................................. 9

2.4 Exhaust Gas Cleaning System Use ........................................................................................... 9

2.5 Uncertainty with EGCS Use ................................................................................................... 10

2.5.1 Nitrogen Oxide (NOx) Requirements ........................................................................... 10

2.5.2 Particulate Matter Requirements ................................................................................... 10

2.5.3 Wash Water ................................................................................................................... 10

Section 3 Life Cycle Cost Analysis ............................................................................................ 12

3.1 Baseline .................................................................................................................................. 12

3.1.1 Analysis Results ............................................................................................................ 13

3.1.2 Vessel/Route Combinations .......................................................................................... 14

3.1.3 Acquisition Costs .......................................................................................................... 14

3.1.4 Expenses ........................................................................................................................ 15

3.1.5 Fuel Futures and Inflation ............................................................................................. 16

3.2 Technology Comparisons ....................................................................................................... 17

3.3 Sensitivity Analyses ............................................................................................................... 18

Section 4 Scrubbing Technology Options ................................................................................. 20

4.1 Wet Systems ........................................................................................................................... 20

4.1.1 Open Loop System ........................................................................................................ 20

4.1.2 Closed Loop System ...................................................................................................... 21

4.1.3 Hybrid System ............................................................................................................... 23

4.1.4 Wet Systems Claiming NOx and CO2 Reductions ....................................................... 24

4.2 Dry Systems ........................................................................................................................... 25

4.3 Fuel Switching ........................................................................................................................ 26

Section 5 Integration, Operations, and Maintenance Practicality ........................................... 28

5.1 Physical Integration Challenges – All Systems ...................................................................... 28

5.2 Open Loop Seawater System .................................................................................................. 29
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Selection Guide, Revision A File No. 10047.01, 22 February 2011 

5.3 Closed Loop Freshwater System ............................................................................................ 30

5.4 Hybrid System ........................................................................................................................ 30

5.5 Dry System ............................................................................................................................. 31

5.6 Summary ................................................................................................................................ 32

Section 6 Discussion ................................................................................................................... 35

6.1 Cost Advantage ...................................................................................................................... 35

6.2 Ship Impacts ........................................................................................................................... 35

6.3 Applicability to non-Ocean Going Vessels ............................................................................ 36

6.4 Environmental Regulations .................................................................................................... 36

6.5 Experience Matters ................................................................................................................. 37

Section 7 References ................................................................................................................... 38

Appendix A Exhaust Scrubber Technology Survey 

Appendix B Life Cycle Costs Tables 

Acknowledgements 

The development of this Guide was made possible through the financial support of the U.S. 

Maritime Administration (MARAD) and the Ship Operations Cooperative Program (SOCP). 

SOCP is a Government Industry Organization whose purpose is to address and promote 

commercial operations through the identification, development, and application of new methods, 

procedures, and technologies. SOCP’s overall objective is to improve the competitiveness, 

productivity, efficiency, safety, and environmental responsiveness of U.S. vessel operations. 

The guidance of SOCP member Susan Hayman of Foss Maritime was invaluable. Johnny 

Eliasson of ABS performed a technical review of the Guide. Paul Smith, Richard Strong, Darren 

Monzingo, and Sean Caughlan of The Glosten Associates provided input and performed 

technical review. 

It is the intent of SOCP to update this Guide annually. Corrections, suggestions for additional 

content, and installation experiences provided by web at www.socp.us or by email to 

programadmin@socp.us will be considered for these updates. 

Revision History 

Section Rev Description Date Approved 

All ― Initial release. 12 January 2011 KJR 

Cover A Added DOT, MARAD, SOCP Logos. 22 February 2011 KJR 

 

2.5.3 A Reworded “local regulatory issue” to 

“potential area of concern.” 

22 February 2011 KJR 

6 A Added Non OGV Discussion 22 February 2011 KJR 
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Selection Guide, Revision A File No. 10047.01, 22 February 2011 

Executive Summary 

As of 2015, ship operators that trade in emissions control areas (ECAs) will be required to burn 

fuel with less than 0.1% sulfur content. A ship operator may meet this requirement by burning 

high-sulfur fuel at sea, and then “switching” to low-sulfur fuel within the ECA. Other ship 

operators may choose to reduce operational efforts by “converting” such that they always burn 

low-sulfur diesel fuel oil, or utilize natural gas that has almost no sulfur content. 

Alternatively, international convention allows a ship operator to burn high-sulfur diesel fuel if 

using an exhaust gas cleaning system (EGCS) that can reach an equivalent level of emission 

reductions. These systems “scrub” most of the sulfur, and some amount of particulate, out of the 

exhaust gas after the high-sulfur fuel is burned. 

This Guide has been developed to assist members of the Ship Operations Cooperative Program 

(SOCP) in determining their emissions requirements, calculating potential cost savings, and 

understanding the integration and operational challenges of various EGCS technologies. Each 

ship operator will need to consider the discussions for and against each EGCS presented herein. 

With the coming deadline of 2015, ship operators considering this option should conduct an 

individual analysis, and consider a prototype installation in the near future. 

Figure 1. Sulfur Emissions Control Strategies 

 
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Selection Guide, Revision A File No. 10047.01, 22 February 2011 

Discussion for EGCS 

The cost of 0.1% distillate fuel oil has historically been 50% higher than higher sulfur marine 

grade residual fuel oils. An analysis of three ship types, each of which operated at least partially 

within an ECA, predicts net present values between $5M and $20M, and internal rates of return 

between 20% and 53%. This assumes operations from 2015 through 2025, and an 8% fuel 

escalation rate. If fuel prices were to escalate at a rate of 11% annually, the net present value 

would increase by almost 50%. These cost savings are so significant that some ship operators 

may find installing an EGCS a competitive necessity. 

Discussion against EGCS 

Most systems are still in their prototype development phase, and therefore carry with them 

technical risks. Even assuming early technical issues are overcome, the ongoing impact of these 

large and complex devices may include: heavy fuel oil heating, purifying, and waste stream 

management; treatment and waste chemical handling and storage; approximate doubling of the 

engine stack size to accommodate scrubber units; weight and stability issues; and additional 

engineering staff to run the machinery and monitoring equipment. Also, it is not yet clear if wet 

scrubbers can remove fine particulates to an equivalent level of reduction as is achieved by 

switching to low sulfur fuel oil. While there is no current requirement for particulate removal, 

the United States Environmental Protection Agency (EPA) published discussions have opened 

this possibility. 

EGCS Ship Candidates 

In general the ship candidates for engaging in this dialogue will meet the following criteria: 

 New and existing ships built before International Maritime Organization (IMO) Tier III 

NOx requirements (Pre-2016 for USCG Category 3 Ships), and 

 The ship burns at least 4,000 metric tons of fuel oil annually within an ECA, for a period 

of at least six years starting in 2015, and 

 The ship passes a technical survey ensuring that an EGCS can be integrated with ship 

arrangements, stability, and operations. For closed loop and dry chemical systems, 

chemical supply chains are confirmed. 

Ships that must comply with the IMO Tier III NOx requirements may not be able to install “wet” 

scrubber style EGCS. These ships will require advanced systems that process NOx and sulfur 

emissions, and possibly fine particulates. 
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Selection Guide, Revision A File No. 10047.01, 22 February 2011 

Section 1 Introduction 

1.1 Sulfur Limit Requirements 

In certain geographic areas, environmental regulations require that ship operators burn lowsulfur fuel to directly limit sulfur-oxide emissions. A secondary, but important 

consideration, is that these measures are expected to indirectly reduce particulate matter 

emissions. As an alternative to utilizing low-sulfur fuel, MARPOL Annex VI recognizes 

exhaust gas cleaning systems (EGCS) provided they provide reductions in sulfur emissions 

at least as effective as that obtained by using low-sulfur fuel. 

The geographic scope of these requirements is a patch-work that includes International 

Maritime Organization (IMO) designated emissions control areas (ECAs), European Union 

(EU) designated port areas, and a California State designated coastal zone. Each of these 

programs has its own phased implementation schedule, but all reach a fuel quality limit of 

0.1% sulfur on or before 1 January 2015. 

ECAs currently in force include the Black Sea and Baltic Sea, and will expand to add the 

North American zone, extending approximately 200 nautical miles offshore, in 2012. Zones 

for Puerto Rico and U.S. Virgin Islands have been accepted, and submittals are being 

prepared for Korea, Japan, and Singapore. Eventually, the ECA scope may include all 

coastal areas of the world. The area outside of ECAs is subject to world-wide limits set by 

IMO. The current world-wide sulfur limit of 4.5% is more generous than typical fuel quality 

which averages 2.7% sulfur by weight. This limit changes, in principal, to a 3.5% sulfur 

limit in 2012. This limit changes, in practice, to a world-wide sulfur limit of 0.5% in either 

2020 or 2025 depending on a fuel availability review to be conducted in the interim. 

1.2 Sulfur Limit Approaches 

Ship operators have several options for complying with the low-sulfur fuel requirements: 

 Fuel Conversion. Convert all fuel storage tanks, fuel piping systems, and 

combustion equipment for compatibility with low-sulfur fuel. The ship will then 

only burn low-sulfur fuel. This might be distillate diesel fuel oil, or natural gas. 

 Fuel Switching. Install a secondary low-sulfur fuel storage and piping system. 

Convert combustion equipment for compatibility for dual (low- and high-sulfur) fuel. 

The ship will then burn low-sulfur fuel when operating inside an ECA, and high 

sulfur fuel when outside ECAs. 

 Exhaust Gas Cleaning System (EGCS). Install an EGCS to scrub sulfur oxides that 

result from burning high-sulfur fuel when operating inside an ECA. 

The term “distillate” is used in this report to refer to light, refined diesel fuel with a sulfur 

content of 0.5% or less. This fuel is called marine gas oil (MGO) in industry, and ISO 

DMA. Marine diesel oil (MDO), ISO DMB, although inclusive of some residual content is 

also considered “distillate” provided sulfur contents are below 0.5%. 

The term “residual” is used to refer to the lesser refined heavy fuel oils, which have current 

have sulfur contents on average of 2.7%. Industrial names for the residual or heavy fuel oil 

(HFO) diesel grades are IFO180 and IFO380, correspondingly ISO RME25 and ISO 

RMG35. 
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Selection Guide, Revision A File No. 10047.01, 22 February 2011 

1.3 Issues Addressed by This Guide 

This Guide has been developed to assist members of the Ship Operators Cooperative 

Program (SOCP) in determining if an EGCS is a practical, lower-cost solution for their fleet. 

Specifically, the Guide addresses key issues as follows: 

 Regulatory Requirements. “What am I required to do?” The Guide will provide a 

basic overview of the regulatory requirements, including phase-in dates and fuel 

sulfur requirements. The requirements for an EGCS will be outlined. The impact of 

nitrogen oxides (NOx) and particulate matter (PM) requirements on an EGCS will be 

discussed. 

 Life-Cycle Cost. “How much fuel cost savings can be realized from an EGCS?” 

The Guide will identify the life-cycle cost of several ECGS technologies for a 

Transpacific Containership, Alaska to Puget Sound Containership, and a U.S. West 

Coast Tankship. These vessel type/route pairs were selected to demonstrate the 

variability in life cycle costs. Additionally, the evaluation provides a base-line cost 

if these vessels did not use scrubbers, but rather just switched from residual to 

distillate. 

 Scrubbing Technology Options. “Which EGCS technology will work for my fleet?” 

The Guide will identify the efficiencies and challenges of the EGCS technologies in 

adequately removing sulfur and particulate from the exhaust stream. The challenges 

can significantly limit an operator’s technology options. For example, open-loop 

systems depends on the alkalinity of ambient seawater, which for low-salinity 

locations can increase the demand for washwater volume to the point where a system 

may not be practical. Closed loop systems solve the low alkalinity challenge with 

the addition of a caustic solution, but at a significant increase in expense and 

logistics. Additionally, scrubbing systems may either hinder or enhance the ship’s 

ability to control other emissions, such as NOx. 

 Operations and Maintenance Practicality. “Can an EGCS be practically integrated 

with ship operations?” The Guide considers the practicality of the various scrubber 

systems. This practicality covers maintenance requirements, the practicality of 

fitting the unit into the machinery space, impact on engine performance, and the 

ability to integrate the system into ship operations and machinery. 

 Discussion. Finally a discussion is provided that pulls together the analysis for the 

ship operator. 

The Appendix provides a technology supplier survey summary including: state of 

technology development, efficacy results, environmental impact evaluations, physical plant 

size, integration efforts, and life-cycle costs. The results of this survey can serve as an initial 

assessment tool for operators that want to further explore EGCS for their fleet. 

The manufacturer’s of these systems have formed the Exhaust Gas Cleaning Systems 

Association (http://www.egcsa.com/ ). The association is a resource for keeping current on 

system promotions and industry provided information: “Member companies of the Exhaust 

Gas Cleaning Systems Association are involved in the development, design and final 

installed configuration and design approval and acceptance of turnkey exhaust gas cleaning 

systems to meet the current and future emissions regulations of IMO and where applicable 

additional regulations introduced by regional and national authorities.” 
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Selection Guide, Revision A File No. 10047.01, 22 February 2011 

Section 2 Sulfur and Other Emissions 

Requirements and Guidelines 

“What am I required to do?” 

This section guides ship operators in identifying applicable air emissions requirements, 

while focusing on opportunities to utilize exhaust gas cleaning systems (EGCS) for 

compliance with sulfur emissions. 

Recent regulatory changes have created continuously evolving and increasingly stringent 

emission standards. Engine manufacturers are required to significantly reduce air emissions 

for both new and remanufactured engines. Lower sulfur fuel and reduced sulfur emissions 

regulations are currently in effect and further reductions are planned in the coming years. 

In general, any ship operating in an ECA will have to either burn low-sulfur fuel or utilize 

an EGCS. The ship operator is also burdened to comply with NOx emissions requirements. 

In general, all EGCS reviewed herein are compatible with IMO Tier I and Tier II NOx 

solutions. Ships built in 2016 or later will need to meet IMO Tier III NOx requirements, 

which may not be compatible with the “wet” scrubber solutions reviewed. 

2.1 Applicability 

Emission regulations are largely dependent on the vessel registry and operational area. The 

following describes the specific requirement applicable to vessels based on their specific 

registry and operating area. 

2.1.1 International 

Ship’s that operate on international voyages are generally subject to the agreements of the 

IMO, as detailed in Annex VI of the International Convention for the Prevention of 

Pollution from Ships (MARPOL). These requirements are comprehensive including 

requirements for low sulfur fuel or sulfur scrubbing, particulate matter and nitrogen oxide 

levels, and hydrocarbon management. In addition, significant recordkeeping and 

certifications are required. 

Flag State is a general term referring to the administration where a ship is registered. Flag 

States that are party to Annex VI are required to enforce the annex within the international 

ocean going fleet that they administer. In some cases, such as the United States, the Flag 

State may have additional requirements. 

Port State is a general term referring to an administration that controls a port(s) where ships 

registered by other administrations may call. Port States that are party to Annex VI have the 

right to board commercial ships arriving from international voyages to determine 

compliance with the Annex. In general, the Port State will review documentation in 

accordance with the Annex, and perform a visual inspection of any installed equipment. 

There are numerous exemptions and exceptions from Annex VI. Ship operators considering 

such exemptions and exceptions should perform a detailed analysis of the Annex, and gain 

acceptance from their Flag State prior to implementing a strategy. In general, exemptions 
Exhaust Gas Cleaning Systems 4 The Glosten Associates, Inc 

Selection Guide, Revision A File No. 10047.01, 22 February 2011 

include: vessels under 400 gross tons (international), diesel engines less than 130 kW 

output, technology research trials, emergency equipment, emergency situations, military and 

government vessels, emissions from sea-bed mineral exploration. There are also time 

phased exemptions for older ships, specifically for engines manufactured prior to 1990. 

Additionally, there are exclusions based on geographical considerations such as transport on 

the US/Canada Great Lakes where regional agreements are more appropriate. 

This Guide does not address ozone depleting substances, volatile organic compounds, 

shipboard incineration or various exemptions and exceptions in depth. 

2.1.2 Emissions Control Areas (ECAs) 

The International Maritime Organization defines two sets of emissions and fuel quality 

requirements within Annex VI. Vessels operating within an Emissions Control Areas 

(ECAs) are required to meet reduced emissions standards and burn lower sulfur fuels. 

Vessels operating outside of these ECAs are required to meet a second set of lesser 

requirements applicable at all remaining locations. 

ECA geographic scope currently in force includes the Black Sea and Baltic Sea, and will 

expand to add the North American zone, extending approximately 200 nautical miles 

offshore, in 2012. Zones for Puerto Rico and U.S. Virgin Islands have been accepted, and 

submittals are being prepared for Korea, Japan, and Singapore. Eventually, the ECA scope 

may include all coastal areas of the world. The area outside of ECA zones is subject to 

world-wide limits set by IMO. 

2.1.3 Federal – United States 

Federal regulation in the United States applies to all vessels flagged or registered in the 

United States. In addition, the U.S. has the authority and has stated that it will enforce IMO 

Annex VI on all U.S. and foreign vessels operating in U.S. waters, as per the Act to Prevent 

Pollution from Ships. U.S. regulation of air emissions is dictated by the U.S. Environmental 

Protection Agency. As such, rather than regulating by the international standard of engine 

speed, diesel powered compression engines are broken into three categories designated by 

the engine cylinder volume. 

Category 3 vessels, those with an engine of cylinder displacements above 30 liters, are 

required to meet equivalent standards to MARPOL Annex VI. In addition, the U.S. is 

finalizing standards for Category 3 engine to control hydrocarbons (HC) and carbon 

monoxide (CO), as well as monitoring of particulate matter (PM) emissions. Control of 

Emissions From New Marine Compression-Ignition Engines at or Above 30 Liters per 

Cylinder (40 CFR Parts 80, 85, 86, et al.) took effect in June 2010. This rule is equivalent to 

the IMO Annex VI that governs ocean going vessels (OGV). Like Annex VI, it includes 

fuel standards targeting sulfur emissions and a phased in schedule for NOx reductions. EPA 

has indicated two important clarifications to the rules governing OGVs: 

 Category 1 and 2 engines on Category 3 vessels can be certified as meeting Annex 

VI instead of gaining EPA certification. 

 OGVs that are Category 1 or 2 vessels and operate offshore extensively, can comply 

with Annex VI as an alternate to meeting EPA designated tier requirements. 
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Selection Guide, Revision A File No. 10047.01, 22 February 2011 

Category 1 and 2 vessels, those with cylinder displacements below 30 liters, that are not 

OGVs are required to meet the more stringent EPA 2008 Final Rule. 

2.1.4 Regional 

Ships are also subject to regional requirements depending on their operating location. Most 

regional requirements are driven by demands particular to the people living in those areas, 

and in some cases topography that results in the acute impact of air emissions on local 

population health. The Los Angeles basin is a primary example of regional requirements, 

where air quality is poor, population density is high, and the public is politically engaged on 

environmental issues. 

Regional requirements are the most likely to change in a short timeframe. Such changes 

provide significant challenges to ship operators that are making air emissions abatement 

decisions. As such, the ship operator must understand the requirements of various port 

locations at which they are likely to call. The programs reviewed in this Guide include: 

 EU Ports. The European Union port locations require either the switching to low 

sulfur fuels or the use of sulfur scrubbers while operating in ports or inland 

waterways. 

 California Coastal Zone. The State of California requires the use of low sulfur fuel 

while operating within its 24 nautical mile coastal zone. California does not 

specifically allow scrubbers as an alternative to burning low sulfur fuels. There are a 

few options for scrubber use that must be reviewed on a case-by-case basis. Also, it 

is the intent of California to sunset the state program once the North American ECA 

comes into effect. 

 Port of Long Beach. The Port of Long Beach has a stated goal to provide electrical 

infrastructure for shore-side power (cold-ironing) at 100% of container terminals. 

2.2 NOx Focused Tier Requirements 

The International Maritime Organization and the Environmental Protection Agency have 

implemented emissions standards in order to reduce emissions from all engines. A tier 

system has been adopted in an effort to phase in lower emission engines as early as possible, 

while setting a long term goal to significantly reducing emissions using an after-treatment 

technology. 

Currently, new engines in vessels subject to Annex VI are required to meet Tier I emissions 

levels. Tier II engines will be required in 2011 as an interim solution to reduce emissions 

until after-treatment based Tier III engines are phased-in in 2014. 

New engines in U.S. flagged category 1 and 2 vessels are required by EPA to meet Tier 2 

emissions levels. Tier 3 engines will be phased-in in 2012 as an interim solution to reduce 

emissions until after-treatment based Tier 4 engines are phased-in in 2014. 

The IMO and EPA have different rules regarding major refits and engine remanufacturing. 

IMO requires vessels built prior to 2000 to meet Tier I emissions levels. Vessels built in 

2000 or later must meet the current standard if possible. The EPA requires engines over 600 

kW to reduce their NOx by 25%, except for Tier 3 engines. EPA has set limits of 2.0 and 5.0 

grams per kilowatt-hour for HC and CO respectively. 
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Selection Guide, Revision A File No. 10047.01, 22 February 2011 

IMO and EPA define various requirements based on vessel build date, engine model year, 

engine power, and displacement. The emission regulations are summarized below in Tables 

4 through 6. 

Wet EGCS impede the use of advanced SCR systems by cooling the exhaust stream, 

wetting the gas stream, and increasing backpressure on the engine. As such, the below 

tables highlight cases where an SCR may be required to meet NOx requirements. 

Table 2. Vessel Emissions Requirements, International & Domestic (EPA Category 3) 

Table 3. Vessel Emissions Requirements, Domestic (EPA Category 1 & 2) 

Table 4. IMO Major Conversion / Remanufactured Engine Tier Requirements 

Registry Operational

Area

Gross

Tons

LOA

(m)

Total

(kW)

Power

(kW)

Bore

(liters)

All International All Vessels Annex VI Sulfur Limits

All International Jan‐00 to Dec‐10 >400 >130 Annex VI Tier I

All International Built after Dec‐10 >400 >130 Annex VI Tier II

All ECA Built after Dec‐15 >400 >24 >750 >130 Annex VI Tier III

US Domestic All Vessels All >30 Per Annex VI

Ship / Engine Particulars

Build Date Requirement

Registry Operational

Area

Power

(kW) Bore (liters)

US Domestic All Vessels EPA Sulfur Limits

US Domestic Jan‐04 + engines >37 >2.5 EPA Tier I = Annex VI Tier I

US Domestic Jan‐04 + engines >37 <2.5 EPA Tier 2

US Domestic Jan‐07 + engines >37 2.5‐30 EPA Tier 2

US Domestic Jan‐12 + engines 75‐3700 <0.9& 3.5‐7 EPA Tier 3

US Domestic Jan‐13 + engines 75‐3700 0.9‐1.2& 2.5‐3.5 EPA Tier 3

US Domestic Jan‐14 + engines 75‐3700 1.2‐2.5 EPA Tier 3

US Domestic Jan‐13 + engines >3700 7‐15 EPA Tier 3

US Domestic Jan‐14 + engines >3700 15‐30 EPA Tier 3

US Domestic Jan‐14 + engines >2000 15‐30 EPA Tier 4

US Domestic Jan‐16 + engines 1400‐2000 <30 EPA Tier 4

US Domestic Jan‐17 + engines 600‐1400 <30 EPA Tier 4

Ship / Engine Particulars

Engine Model Requirement

Year

Registry

Operational

Area

Gross

Tons

Major Conversion /

Remanufacture Date

All International before Jan‐00 >400 Any Annex VI Tier I

All International after Dec‐99 >400 Jan‐00 to Dec‐10 Annex VI Tier I

All International after Dec‐99 >400 after Dec‐10 Annex VI Tier II

All ECA after Dec‐99 >400 after Dec‐15 Annex VI Tier III

Requirement

Ship / Engine Particulars

Build Date
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Selection Guide, Revision A File No. 10047.01, 22 February 2011 

Table 5. EPA Major Conversion / Remanufactured Engine Tier Requirements 

2.2.1 IMO Annex VI NOx Details 

Regulation 13 of IMO Annex VI applies to non-emergency marine diesel engines with an 

output of more than 130 kW installed or substantially modified on or after 1 January 2000. 

NOx limitations for these engines are tiered as indicated below, where n = rated engine 

speed. The Regulation includes numerous exceptions, including engines only used in an 

emergency and in minerals exploration. Figure 2 and Table 6 present the IMO Annex VI 

Tier NOx requirements. 

Figure 2. IMO Annex VI Tier NOx Requirements 

Registry

Operational

Area EPA Tier

Power

(kW)

Remanufacture

Date

US Domestic Tier 0 >600 after Jan‐00 Tier 0+ (25% NOx Reduction)

US Domestic Tier 1 >600 after Jan‐00 Tier 1+ (25% NOx Reduction)

US Domestic Tier 2 >600 after Jan‐13 Tier 2+ (25% NOx Reduction)

US Domestic Tier 3 >600 Any Tier 3

Engine Particulars

Requirement

17 17

13.0

11.3

10.4

9.8 9.8

14.4 14.4

10.5

9.0

8.2

7.7 7.7

3.4 3.4

2.6 2.3 2.1 2 2

0

2

4

6

8

10

12

14

16

18

0 500 1000 1500 2000 2500

Nitrogen Oxides(grams/kW‐hr)

Engine Speed (rotations per minute)

NitrogenOxide Requirements ‐ IMO Annex VI

Tier I (2000 ‐ 2010 Build) Tier II (2011 ‐ 2015 Build) Tier III (2016 Onward Build)

130 RPM, Low Speed

2000 RPM, High Speed
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Selection Guide, Revision A File No. 10047.01, 22 February 2011 

Table 6. IMO Annex VI Tier NOx Requirements 

2.2.2 EPA Category 1 and 2 Tier Details 

The EPA marine engine emissions are regulated by a number of different rules, each 

contributing to the current four tier rating system. Emission regulations vary by power, 

cylinder displacement, and model year. 

In general, Tier 1 requirements are similar to the IMO Annex VI Tier I requirements. Tier 2 

and Tier 3 regulation incrementally reduce emissions with the intent that manufacturers can 

meet the requirements through modifications to piston rings, cylinder walls, timing, and fuel 

management. This is similar to the intent of IMO Annex VI Tier II requirements. 

EPA Tier 4 emissions limits will require engines to use after-treatment devices similar to the 

IMO Annex VI Tier III requirements. The EPA Tier 4 standard is very similar to the IMO 

Annex VI Tier III. 

Specific EPA emission requirements including NOx, HC, and PM limits can be found in 40 

CFR Parts 9 and 85. 

2.3 Sulfur Requirements 

The EGCS market is being driven by regulatory requirements to reduce ship emissions of 

sulfur oxides. Ships have the option of either using a low sulfur fuel oil or scrubbing their 

exhaust gas to an equivalent sulfur level. The following table summarizes the low sulfur 

phase-in dates specified in each of the presented regulations. 

Table 7. Low Sulfur Phase-In Dates 

2.3.1 MARPOL Annex VI, 2008 

Oceans: The current marine bunker fuel sulfur limit of 4.5% is reduced to 3.5% in 2012. A 

further reduction to 0.5% will be reviewed in 2018, with implementation options of 2020 or 

Rated Speed

Less than 130

RPM

131 Through

2,000 RPM

Greater than

2,000 RPM

Construction Date (g/kW‐hr) (g/kW‐hr) (g/kW‐hr)

Tier I.   2000 ‐ 2010 17 45 * n^‐0.2 9.8

Tier II.  2011 ‐ 2015 14.4 44 * n^‐0.23 7.7

Tier III. 2016Onward 3.4 9 * n^‐0.2 2

Category 3 Ships

Starting Year

(Jan 1st) Oceans

Emission

Control

Areas EU Ports

California

Coastal

Cat. 1 & 2

Ships

2010 4.5% 1.0% 0.1% 0.5% * 0.0500%

2012 3.5% 1.0% 0.1% 0.1% 0.0015%

2015 3.5% 0.1% 0.1% 0.1% 0.0015%

2020 (2025) ** 0.5% 0.1% 0.1% 0.1% 0.0015%

*0.5% Marine Gas Oil, or 0.1% Marine Diesel Oil

**Implementation of Oceans limit at 0.5% Sulfursubject to review in 2018
Exhaust Gas Cleaning Systems 9 The Glosten Associates, Inc 

Selection Guide, Revision A File No. 10047.01, 22 February 2011 

2025. There is considerable debate as to whether the 0.5% requirement will be met with 

distillate or residual fuel. This report assumes that desulfurization of residual fuel will be 

the more common approach. 

Emissions Control Areas: The current marine bunker fuel sulfur limit of 1.0% is further 

reduced to 0.1% in 2015. To practically achieve 0.1% sulfur, use of distillate is required. 

2.3.2 EU Ports (Directive 2005/33/EC of the European Parliament and of 

the Council) 

Marine bunker fuel sulfur limits apply to inland waterway vessels and ships at berth. “At 

berth” effectively limits the requirement to auxiliary loads while dockside or at anchor. The 

current 1.5% limit applies to passenger vessels, and vessels operating in the Baltic and North 

Seas. January 2010 limits all vessels to 0.1%, effectively requiring a distillate fuel. 

2.3.3 California Coastal (California Air Resources Board) 

Current marine bunker fuel options for ocean going vessels (OGVs) are either marine gas oil 

(DMA) limited to 1.5% sulfur, or marine diesel oil (DMB) limited to 0.5% sulfur (see 

asterisk in above table). These grades of distillate fuels are expected to reduce particulate 

matter significantly in exhaust emissions. January 2012 allows use of either of these 

distillate fuels, but with a limit of 0.1% sulfur. Category 1 and 2 vessels are limited to 15 

ppm sulfur fuel (0.0015%). 

2.3.4 US – EPA Category 1 and 2 Engine Vessels 

With the implementation of higher Tiers (3 and 4) of regulation for Category 1 and 2 

engines, the EPA has mandated the supply chain to distribute lower sulfur content in fuel. 

As of 2010, all marine fuel is required to contain 1,000 ppm (0.1000%) of sulfur or less. 

Then in 2012, locomotive and marine fuel is required to be ULSD, or less than 15 ppm 

(0.0015%) of sulfur. EPA has indicated two important clarifications to the rules governing 

U.S. Flagged ocean going vessels (OGVs): 

 Category 1 and 2 engines on Category 3 vessels can be certified as meeting Annex 

VI instead of gaining EPA certification. 

 OGVs that are Category 1 or 2 vessels and operate offshore extensively, can comply 

with Annex VI as an alternate to meeting EPA designated tier requirements. 

2.4 Exhaust Gas Cleaning System Use 

The IMO and EPA both recognize Exhaust Gas Cleaning Systems (EGCS) as acceptable 

alternatives to low sulfur fuels. 

The IMO 2008 Guidelines for Exhaust Gas Cleaning Systems (Guidelines) specifies the 

process for testing, certification, and verification for the use of exhaust gas cleaning systems 

(ECGS). The Guidelines provide specific requirements for measuring of the sulfur content 

in the exhaust gas and monitoring wash water discharge quality, including pH changes and 

contaminant levels. This regulation is continuing to evolve as technology providers gain 

application experience. 

Compliance with IMO sulfur reduction requirements options are detailed in the Guidelines 

and termed Scheme A – Type Approval, and Scheme B – Continuous Emissions Monitoring 

(CEM). The Scheme A approach demands a significant testing and approval process 
Exhaust Gas Cleaning Systems 10 The Glosten Associates, Inc 

Selection Guide, Revision A File No. 10047.01, 22 February 2011 

resulting in a Type Approval. The Scheme B approach requires the use of sophisticated 

emissions monitoring equipment. Such a monitoring system however, although to perhaps a 

somewhat lower standard, will still be required for Scheme A systems. 

EPA provides guidance in its Vessel General Permit program regarding wash water 

requirements, and follows the IMO Guidelines. However, the EPA has instituted a 

particulate matter testing program for Category 3 engines, and may in the future define PM 

requirements related to the use of EGCS. 

2.5 Uncertainty with EGCS Use 

There are a number of sources for uncertainty that must be understood before selecting an 

EGCS. These include technology compatibility among both current and future required 

equipment technology. Additionally, future regulatory changes both on sulfur, NOx and PM 

will affect the practicality of implementing an EGCS. 

Scrubber suppliers use different designs, and have different water and power requirements. 

As such, the ship operator should study the engineering details of several providers before 

making a selection decision. 

2.5.1 Nitrogen Oxide (NOx) Requirements 

Ship operators must consider requirements for the abatement of NOx when selecting a 

suitable sulfur abatement strategy. In general, sulfur scrubbers are compatible with NOx 

abatement strategies, such as engine tuning, that target currently enforced IMO Tier I/II and 

EPA Tier 1/2/3 emission limit. This strategy is compatible as it does not significantly 

impact engine backpressure that is important to EGCS. 

However, some sulfur scrubbers are not compatible with NOx abatement strategies, such as 

selective catalytic reduction (SCR), that target the IMO Tier III and EPA Tier 4 NOx 

requirements that phase-in starting in 2016. SCRs work best with hot, dry, low sulfur 

exhaust streams. Also, the combined EGCS and SCR use will require fan use to avoid 

excessive backpressure on the engines. As such, NOx requirements will not significantly 

affect the adoption of sulfur scrubbers until 2016, when more advanced NOx abatement 

technologies will be required. 

2.5.2 Particulate Matter Requirements 

EPA is currently in a program that is evaluating the efficiency of PM10 and PM2.5 

reduction resulting from diesel combustion of low sulfur fuels. It is possible that a PM limit 

will be added to EGCS requirements. There is uncertainty as to the efficacy of EGCS in the 

removal of particulate matter, in particular PM2.5. 

2.5.3 Wash Water 

Wash water discharge impacts local water quality, and as such will remain a potential area 

of concern. It is possible that local regulations will develop, or that local environmental 

concerns will be voiced over wash water discharges in certain areas. This creates 

uncertainty for the use of open loop scrubbers in certain environmentally sensitive areas. 

The monitoring of wash water, as per IMO guidance, includes polycyclic aromatic 

hydrocarbons (PAH) and turbidity. These instruments require significant effort to maintain 

and keep in calibration. 
Exhaust Gas Cleaning Systems 11 The Glosten Associates, Inc 

Selection Guide, Revision A File No. 10047.01, 22 February 2011 

Table 8. Regulatory Compliance Overview 

Nitrogen oxide Tiers I, II, and III are IMO standards. Tiers 1, 2, 3, and 4 are EPA standards. 

Compliance Options

Low Sulfur

Fuels

Engine

Modifications

Sulfur

Scrubbers

Advanced

Technologies

Sulfur Regulations

1.5% S ACAB

0.5% S ACAB

0.1% S ACAB

Particulate Matter

PM2.5 B C C B

PM10 B B B B

Nitrogen Oxides

Tier I / Tier 1 CBCB

Tier II / Tier 2& 3C B C B

Tier III/ Tier 4 CCDB

Key:   A ‐ Full Solution,    B ‐ Varies by Technology, Possible Full Solution

        C ‐ Typically Not a Solution but Likely Compatible with Other Solutions

        D ‐ Typically Not a Solution and Likely Not Compatible with Other Solutions
Exhaust Gas Cleaning Systems 12 The Glosten Associates, Inc 

Selection Guide, Revision A File No. 10047.01, 22 February 2011 

Section 3 Life Cycle Cost Analysis 

“How much fuel cost savings can be realized from an EGCS?” 

Exhaust gas cleaning systems (EGCSs) offer potential fuel cost savings for ships that 

operate in emissions control areas (ECAs). Although California and EU Ports currently 

require significantly low sulfur levels in marine fuel, widespread implementation takes place 

in 2015 when 0.1% sulfur “distillate” fuel, or an EGCS, becomes mandatory. Potential cost 

saving is the product of fuel consumed in an ECA and the cost differential between distillate 

and residual fuel. This savings is then reduced by EGCS capital and operating expenses, 

including crew, maintenance and repair, consumed chemicals, and machinery loads. 

ݏ݅݊݃ݒܵܽ ݐݏ݋ܥ ݈݁ݑܨ

ሻ݈݅ܽݐ݁݊ݎ݂݂݅݁ܦ ݐݏ݋ܥ ݁ݐ݈݈݅ܽݐݏ݅ܦ כ ݊݋݅ݐ݌݉ݑݏ݊݋ܥ ݈݁ݑܨ ܣܥܧሺ ൌ

ሻݏ݁ݏ݁݊݌ݔܧ ݅݊݃ݐܽݎ݁݌ܱ ܽ݊݀ ݈ܽݐ݅݌ܽܥ ܵܥܩܧሺ െ

This section provides life cycle cost analysis (LCCA) examples designed to inform the ship 

operator of the key variables that impact life cycle cost, and key uncertainties that will have 

a substantial impact on potential projects budget. It is envisioned that the ship operator will 

set-up a customized LCCA for their own ship or fleet. This analysis is broken into the 

following parts: 

 Baseline. Three ship/route combinations are analyzed to highlight the impacts of 

quantity of fuel consumed in an ECA. One baseline ship is used for the remaining 

analysis. 

 Technology cost differences. Four scrubber technologies are analyzed to review the 

impact of capital and operating expenses on life cycle. 

 Uncertainty and Sensitivity. Factors that a ship operator can neither predict nor 

reliably control are reviewed. The baseline ship is then used to demonstrate analysis 

sensitivity to both uncertain factors, and those the ship operator can control. 

3.1 Baseline 

A baseline life cycle cost analysis is provided in Table 9 for three ship/route pairs. This 

side-by-side analysis estimates different capital expenses for installing a similar EGCS on 

each ship due to differences in propulsion plant sizes. The annual fuel consumption within 

an ECA for each ship is a function of ship propulsion, ship service, and cargo loads, as well 

as the ship’s route and ports of call. 

The remainder of the key variables are consistent for each ship/route pair. This includes 

predicted fuel cost differentials for distillate, inflation and labor rates, and EGCS operating 

expenses. 
Exhaust Gas Cleaning Systems 13 The Glosten Associates, Inc 

Selection Guide, Revision A File No. 10047.01, 22 February 2011 

Table 9. Life Cycle Cost Analysis, Baseline for Three Ship/Route Pairs 

3.1.1 Analysis Results 

The analysis demonstrates that the quantity of fuel consumed within an ECA is the key 

driver of the potential savings through the project life cycle. Capital equipment cost is also 

important as a one-time expense that extends the investment payback period. 

The net present value for all three pairs is positive, ranging from approximately five to 

twenty million in U.S. dollars, with the higher value corresponding to the higher in ECA 

fuel consumption. 

Ship/Route Pair

Containership

Transpacific

Containership

Alaska to

Puget Sound

Tankship US

West Coast

Scrubber Type Open Loop Open Loop Open Loop

VARIABLES ‐ CONTROLLED

Investment Terms

Life Cycle (# of Years) 10 10 10

Analysis Date (Today) (Year) 2011 2011 2011

Scrubber Installation Date (Year) 2014 2014 2014

Discount Rate (%) 10.0% 10.0% 10.0%

Capital Expense for Scrubber

Equipment (Today) (USD/One Time) $5,260,000 $5,060,000 $3,960,000

Engineering/Design (% Equip Cost) 7.0% 7.0% 7.0%

Training/Documents (% Equip Cost) 2.0% 2.0% 2.0%

Install/Commission (% Equip Cost) 50.0% 50.0% 50.0%

Operating Expense ‐ Annual

ECA Fuel Consumption (MT/Annual) 6,212 9,636 10,840

Chemical Consumption (% of Fuel Cost) 0.0% 0.0% 0.0%

Scrubber Parasitic Loads (% of Fuel Cost) 2.0% 2.0% 2.0%

Distillate Calorie Correction (% of Fuel Cost) 4.0% 4.0% 4.0%

HFO Process and Heating (% of Fuel Cost) 0.8% 0.8% 0.8%

Operating Engineer (Today) (USD/Annual) $292,000 $292,000 $292,000

Operating Engineer (% of Position) 50.0% 50.0% 50.0%

M&R Equipment (% Equip Cost/Annual) 4.0% 4.0% 4.0%

Variables ‐ Uncertain

Fuel Differential (Today) (USD/MT) $255.50 $255.50 $255.50

Fuel/Chemical Escalation Rate (% ‐ Annual for Op Period) 8.0% 8.0% 8.0%

Personnel Inflation Rate (% ‐ Annual for Op Period) 3.0% 3.0% 3.0%

Equipment Inflation Rate (% ‐ Annual for Op Period) 3.3% 3.3% 3.3%

Analysis Results ‐ Overview (Nearest $1,000)

Capital Cost (USD ‐ Year Zero Dollars) (9,219,000) (8,868,000) (6,941,000)

Expenses ‐ Year One (USD ‐ Year One Dollars) (551,000) (623,000) (601,000)

Fuel Savings ‐ Year One (USD ‐ Year One Dollars) 2,159,000 3,350,000 3,768,000

Net Present Value (USD ‐ 2011 Dollars) 4,851,000 14,562,000 20,110,000

Internal Rate of Return (%) 20% 36% 53%
Exhaust Gas Cleaning Systems 14 The Glosten Associates, Inc 

Selection Guide, Revision A File No. 10047.01, 22 February 2011 

The internal rate of return (IRR) ranges from 20% to 53%, with the highest return 

corresponding to the highest ECA fuel consumption. Each ship operator will need to set the 

minimum rate of return for themselves. 

Assumptions and annual calculations to support the tables in this section may be found in 

the Appendix. 

3.1.2 Vessel/Route Combinations 

Three vessel/route combinations were selected to demonstrate the impact of fuel 

consumption within an ECA on life cycle cost. 

Transpacific containership. This 4,000 TEU ship transits between Shanghai, Los Angeles, 

and Oakland in a round trip of 25 days at 23 knots. It operates a 36 megawatt propulsion 

plant at 30.2 megawatts to maintain speed. A combined 3,000 kilowatt ship’s service plant 

typically runs at 1,200 kilowatts, increasing to 2,000 kilowatts while in port. Annual fuel 

consumption estimated at 35,000 metric tons, with 6,200 in an ECA. This assumes that 

Shanghai will be an ECA by 2015. 

Containership Puget Sound to Alaska. This 2,000 TEU ship transits between Tacoma and 

Anchorage in a round trip of 7 days at 20 knots. It operates a 16 megawatt propulsion plant 

at 14.7 megawatts to maintain speed. A combined 3,000 kilowatt ship’s service plant 

typically runs at 800 kilowatts, increasing to 1,600 kilowatts while in port. Annual fuel 

consumption estimated at 19,000 metric tons, with 9,600 in an ECA. This assumes that the 

ship would divert course to outside of the ECA for 50% of its voyage starting in 2015 once 

distillate fuel consumption is required. 

Tankship US West Coast. This 60,000 DWT product carrier transits between Anacortes and 

Long Beach in a round trip of 8 days at 14.5 knots. It operates a 10 megawatt propulsion 

plant at 9 megawatts to maintain speed. A combined 3,000 kilowatt ship’s service plant 

typically runs at 350 kilowatts, increasing to 2,350 kilowatts while in port. Annual fuel 

consumption estimated at 11,000 metric tons, all of which will be within an ECA beginning 

is 2015. 

3.1.3 Acquisition Costs 

For each of the subject ships, acquisition costs of scrubbing technologies have been broken 

down into equipment, engineering/design, installation/commissioning, and training/ 

documentation costs. 

Equipment costs shown in Table 10 are based on budget estimates provided by the 

equipment suppliers for this analysis. These budgets were normalized such that each covers 

roughly the same scope of supply, such as equipment engineering, equipment supply, and 

installation oversight. In each case, each propulsion engine is paired with a single scrubber 

unit, and multiple electric generating units are served by a single scrubber unit. Where 

multiple suppliers provided budgets for the same technology, they were generally averaged. 

Actual prices for ship-specific scrubber systems must be obtained directly from the 

suppliers, in order to account for arrangements and other specifics. 
Exhaust Gas Cleaning Systems 15 The Glosten Associates, Inc 

Selection Guide, Revision A File No. 10047.01, 22 February 2011 

Table 10. Estimated Scrubber Equipment Only Costs for Subject Ships 

Installation and commissioning is assumed to be 50% of the equipment cost for all 

technologies. Other costs are also based on percentages of equipment cost: 7% for 

engineering/design, and 2% for training and documentation. 

Given that very few scrubbers have been installed, there is uncertainty with both the 

equipment costs and the support costs. Also, each ship is unique and will require a custom 

cost estimate. As such, these budgets are rough order of magnitude. 

3.1.4 Expenses 

Maintenance and repair expenses are assumed to be 4% annually of the equipment costs. 

For operations, it is assumed that an additional engineer will be required spending at least 

half time on scrubber operations. The cost of the engineer will vary significantly based on 

the flag of the ship. 

Consumables and parasitic loads have been converted to a percentage of fuel consumption. 

For closed loop and dry scrubbers, chemical supply lines and costs are significant. Caustic 

soda prices are highly volatile, with the “free on board” cost per metric ton escalating from 

$270 in August to $340 in October of 2010. Although these fluctuations do not necessarily 

follow fuel prices, this analysis links the two. It is assumed that caustic soda will average 

50% the cost of residual fuel oil on a weight basis. The amount of caustic soda consumed, is 

based on supplier information assuming 2.7% sulfur fuel. 

Burning residual fuel requires significant heating, purifying, and waste management efforts 

that require energy, maintenance, and operational efforts. Typically the tanks and 

combustion fuel lines are heated by waste heat generated steam, meaning that energy costs 

are relatively low. A small percentage, 0.8% of fuel consumption, is assumed to be 

expended managing the residual fuel oil. 

A 5% correction factor is applied to account for the difference in heating value of distillate 

on a weight basis, as compared to residual fuel. On the other hand distillate is lighter, and 

therefore requires a higher volume for storage, and more importantly for piping work and 

mechanical systems. This volume difference results in a diesel engine energy loss. The 

Open Loop Closed Loop Hybrid Dry

Scrubber Ratings

(by Engine Size) (USD) (USD) (USD) (USD)

36MW 3,100,000 3,850,000 3,600,000 6,050,000

16MW 2,900,000 3,600,000 3,120,000 3,200,000

12MW 2,000,000 2,500,000 2,220,000 1,900,000

10MW 1,800,000 2,150,000 1,920,000 1,600,000

3MW 1,300,000 1,850,000 1,560,000 1,250,000

1MW 1,000,000 1,750,000 1,260,000 930,000

Containership

Transpacific 5,260,000 6,430,000 5,904,000 7,970,000

Containership Alaska

to Puget Sound 5,060,000 6,180,000 5,424,000 5,120,000

Tankship US West

Coast 3,960,000 4,730,000 4,224,000 3,520,000
Exhaust Gas Cleaning Systems 16 The Glosten Associates, Inc 

Selection Guide, Revision A File No. 10047.01, 22 February 2011 

baseline assumes an aggregate 4% reduction in weight based fuel consumption when 

burning distillate. 

3.1.5 Fuel Futures and Inflation 

There is no consensus on future fuel prices. More importantly to scrubber life cycle costs is 

the fuel cost differential between residual fuel and distillate fuel. Bunkerworld.com listed 

Los Angeles IFO380 at $540.50, and MGO at $796.00 on 11 January 2011. This differential 

is $255.50 per metric ton, or a 47% premium for the low sulfur distillate fuel. 

Fuel cost predictions on this differential fall into the following general categories: 

 In 2015 distillate will become scarce because of the demand created by ships 

attempting to comply with ECA requirements. The distillate premium will then 

escalate very quickly, as refineries are forced to employ energy intensive and 

expensive means of refining more distillate. 

 There is a fixed amount of energy and effort to refine distillate. Therefore, the 

distillate premium over residual fuel should remain steady, accounting for inflation. 

 The premium for low sulfur distillate (marine gas oil) has generally been 50% over 

residual fuel, and is likely to remain that way. 

This analysis assumes that the distillate premium will be 50% above the price of residual 

fuel. As a baseline, this analysis assumes fuel price escalation at 8% annually as generally 

supportive of a ten-year life cycle for a system installation. 

Currently, inflation as measured by the consumer and producer price indices is low. 

However, this analysis is looking at expenditures that target ship operations over a long term 

period from 2015 through 2025. We have elected to use rates of 3.3% for PPI and 3.0% for 

CPI are assumed in the baseline. 

Ship operators are encouraged to utilize their own predictions for energy prices and inflation 

in future years. 
Exhaust Gas Cleaning Systems 17 The Glosten Associates, Inc 

Selection Guide, Revision A File No. 10047.01, 22 February 2011 

3.2 Technology Comparisons 

The vessel/route comparisons demonstrated that fuel consumption volumes within an ECA 

are the key factor in predicting the economic advantage of a scrubber. This section focuses 

on the Containership Alaska to Puget Sound ship/route pair in order to compare the impact 

of various EGCS technologies on life cycle cost. 

Table 11. EGCS Technology Impact on Life Cycle Cost 

All technologies show positive net present values, and relatively high IRR ranging from 

25% for the closed loop scrubber, to 36% for the open loop scrubber. Although there is a 

fiscal advantage for the open loop scrubber, net present value shows adequate margin to 

allow a ship operator to select the most appropriate technology for their operation. 

Ship/Route Pair

Containership

Alaska to

Puget Sound

Containership

Alaska to

Puget Sound

Containership

Alaska to

Puget Sound

Containership

Alaska to

Puget Sound

Scrubber Type Open Loop Closed Loop Hybrid Dry

Sensitivity Analysis Scrubber Types Open Loop Closed Loop Hybrid Dry

VARIABLES ‐ CONTROLLED

Investment Terms

Life Cycle (# of Years) 10 10 10 10

Analysis Date (Today) (Year) 2011 2011 2011 2011

Scrubber Installation Date (Year) 2014 2014 2014 2014

Discount Rate (%) 10.0% 10.0% 10.0% 10.0%

Capital Expense for Scrubber

Equipment (Today) (USD/One Time) $5,060,000 $6,180,000 $5,424,000 $5,120,000

Engineering/Design (% Equip Cost) 7.0% 9.0% 9.0% 11.0%

Training/Documents (% Equip Cost) 2.0% 2.0% 2.0% 2.0%

Install/Commission (% Equip Cost) 50.0% 65.0% 75.0% 85.0%

Operating Expense ‐ Annual

ECA Fuel Consumption (MT/Annual) 9,636 9,636 9,636 9,636

Chemical Consumption (% of Fuel Cost) 0.0% 3.0% 1.5% 3.0%

Scrubber Parasitic Loads (% of Fuel Cost) 2.0% 1.0% 1.5% 1.0%

Distillate Calorie Correction (% of Fuel Cost) 4.0% 4.0% 4.0% 4.0%

HFO Process and Heating (% of Fuel Cost) 0.8% 0.8% 0.8% 0.8%

Operating Engineer (Today) (USD/Annual) $292,000 $292,000 $292,000 $292,000

Operating Engineer (% of Position) 50.0% 65.0% 65.0% 65.0%

M&R Equipment (% Equip Cost/Annual) 4.0% 4.0% 4.0% 4.0%

Variables ‐ Uncertain

Fuel Differential (Today) (USD/MT) $255.50 $255.50 $255.50 $255.50

Fuel/Chemical Escalation Rate (% ‐ Annual for Op Period) 8.0% 8.0% 8.0% 8.0%

Personnel Inflation Rate (% ‐ Annual for Op Period) 3.0% 3.0% 3.0% 3.0%

Equipment Inflation Rate (% ‐ Annual for Op Period) 3.3% 3.3% 3.3% 3.3%

Analysis Results ‐ Overview (Nearest $1,000)

Capital Cost (USD ‐ Year Zero Dollars) (8,868,000) (11,990,000) (11,121,000) (11,175,000)

Expenses ‐ Year One (USD ‐ Year One Dollars) (623,000) (790,000) (722,000) (742,000)

Fuel Savings ‐ Year One (USD ‐ Year One Dollars) 3,350,000 3,350,000 3,350,000 3,350,000

Net Present Value (USD ‐ Present Dollars) 14,562,000 10,185,000 11,574,000 11,336,000

Internal Rate of Return (%) 36% 25% 28% 27%
Exhaust Gas Cleaning Systems 18 The Glosten Associates, Inc 

Selection Guide, Revision A File No. 10047.01, 22 February 2011 

The open loop technology holds a financial advantage because both capital and operating 

expenses are less. The system has the fewest number of components resulting in lower cost 

for engineering and installation 

Higher engineering, installation, and operating expenses are assumed for the closed loop and 

hybrid systems. This is a function of the chemical consumable that requires holding tanks, 

handling systems, labor to move on board, and disposal of the waste product. The dry 

system sees an additional installation cost increase due to the large dry chemical hopper 

tanks and conveyor systems that require installation, operations, and maintenance. 

3.3 Sensitivity Analyses 

A ship operator has some control, or ability to predict, the amount of fuel that will be burned 

within an ECA, the operating life of the ship/system, and crew baseline salaries. These are 

primary factors in determining life cycle cost. However, there are other factors that are 

more difficult to predict. This includes fuel escalation and inflation rates, as well as some 

risk with the installation costs of the project. 

This section continues with the Containership Alaska to Puget Sound in order to determine 

the sensitivity of the analysis to these variables. Following these descriptions, a table is 

provided that considers several combinations of these sensitive variables in attempt to 

bracket fiscal risk of an EGCS project. Table 12 brackets the best case IRR at 62%, and the 

worst case IRR as 6% for the baseline ship. 

ECA Fuel Consumption Volume – High Sensitivity. The baseline assumed that the ship 

burned roughly 50% of its fuel in an ECA for an IRR of 36%. If the ship must stay within 

the ECA 75% or 100% of the time, the IRR increases to 55% and 73% respectively. The 

same ship, if it were to only burn 4,000 metric tons (~21% of its annual consumption) would 

have a negative NPV. As such, this is considered a minimum fuel consumption volume for 

EGCS consideration for an ocean going ship. 

Inflation and Fuel Cost Escalation – Moderate Sensitivity. Inflation as it impacts equipment 

and labor costs has a negative impact on EGCS life cycle costs. However, if that inflation 

also impacts distillate fuel cost differentials, the net impact is positive. The net result is that 

the two forces work to counter-act each other to some extent. The baseline example 

assumes 3% CPI, 3.3% PPI, and 8% fuel escalation on an annual basis for an IRR of 36%. 

A high inflation period of 5% for CPI and PPI, and 11% for fuel results in an IRR of 44%. 

A low inflation period of 2% CPI and PPI, and 5% for fuel results in an IRR of 24%. 

Operating life – Moderate Sensitivity. The baseline operating life is ten years, providing a 

return of 36%. If the operating life is extended to 15 or 20 years, the IRR remains relatively 

flat at 39%. However, it should be noted that the NPV increases from $14.5M to $25.1M to 

$34.9M for 10, 15, and 20 years respectively. An operating life of less than four years 

yields a negative NPV. 

Expenses – Moderate Sensitivity. The sensitivity of expenses was analyzed by adjusting all 

expenses from equipment costs, to engineer salary, to amount of time the engineer works on 

equipment by an increase of 25% for a worst case, and decreasing by 25% for a best case. 

The best case and worst case result in 55% and 28% IRR respectively. 
Exhaust Gas Cleaning Systems 19 The Glosten Associates, Inc 

Selection Guide, Revision A File No. 10047.01, 22 February 2011 

Combinations – High Sensitivity. Table 12 provides worst and best case combinations for 

our baseline ship/route pair, a ten-year life cycle, and an assumed discount rate of 10%. The 

worst case assumes that fuel price escalation averages only 2%, and that expenses are 

generally 25% higher than expected. The best case assumes a fuel price escalation on 

average of 11% with expenses lower by 25%. The resulting IRR ranges from 6% to 62%, 

with the worst case indicating a negative NPV. 

Table 12. Life Cycle Cost Sensitivity, Combinations for Worst/Best Cases 

Ship/Route Pair

Containership

Alaska to

Puget Sound

Containership

Alaska to

Puget Sound

Containership

Alaska to

Puget Sound

Containership

Alaska to

Puget Sound

Scrubber Type Open Loop Open Loop Open Loop Open Loop

Sensitivity Analysis Expenses Low Predicted High V. High

Combination of Variables Fuel/CPI‐PPI 11/5 8/3 5/2 2/1

VARIABLES ‐ CONTROLLED

Investment Terms

Life Cycle (# of Years) 10 10 10 10

Analysis Date (Today) (Year) 2011 2011 2011 2011

Scrubber Installation Date (Year) 2014 2014 2014 2014

Discount Rate (%) 10.0% 10.0% 10.0% 10.0%

Capital Expense for Scrubber

Equipment (Today) (USD/One Time) $3,795,000 $5,060,000 $5,566,000 $6,325,000

Engineering/Design (% Equip Cost) 5.0% 7.0% 9.0% 11.0%

Training/Documents (% Equip Cost) 2.0% 2.0% 2.0% 2.0%

Install/Commission (% Equip Cost) 40.0% 50.0% 60.0% 65.0%

Operating Expense ‐ Annual

ECA Fuel Consumption (MT/Annual) 9,636 9,636 9,636 9,636

Chemical Consumption (% of Fuel Cost) 0.0% 0.0% 0.0% 0.0%

Scrubber Parasitic Loads (% of Fuel Cost) 2.0% 2.0% 2.0% 2.0%

Distillate Calorie Correction (% of Fuel Cost) 4.0% 4.0% 4.0% 4.0%

HFO Process and Heating (% of Fuel Cost) 0.8% 0.8% 0.8% 0.8%

Operating Engineer (Today) (USD/Annual) $200,000 $292,000 $350,000 $400,000

Operating Engineer (% of Position) 25.0% 50.0% 75.0% 100.0%

M&R Equipment (% Equip Cost/Annual) 2.0% 4.0% 6.0% 8.0%

Variables ‐ Uncertain

Fuel Differential (Today) (USD/MT) $255.50 $255.50 $255.50 $255.50

Fuel/Chemical Escalation Rate (% ‐ Annual for Op Period) 11.0% 8.0% 5.0% 2.0%

Personnel Inflation Rate (% ‐ Annual for Op Period) 5.0% 3.0% 2.0% 1.0%

Equipment Inflation Rate (% ‐ Annual for Op Period) 5.0% 3.3% 2.0% 1.0%

Analysis Results ‐ Overview (Nearest $1,000)

Capital Cost (USD ‐ Year Zero Dollars) (6,458,000) (8,868,000) (10,100,000) (12,405,000)

Expenses ‐ Year One (USD ‐ Year One Dollars) (407,000) (623,000) (849,000) (1,124,000)

Fuel Savings ‐ Year One (USD ‐ Year One Dollars) 3,737,000 3,350,000 2,993,000 2,665,000

Net Present Value (USD ‐ Present Dollars) 25,397,000 14,562,000 6,372,000 (1,964,000)

Internal Rate of Return (%) 62% 36% 22% 6%
Exhaust Gas Cleaning Systems 20 The Glosten Associates, Inc 

Selection Guide, Revision A File No. 10047.01, 22 February 2011 

Section 4 Scrubbing Technology Options 

“Which EGCS technology will work for my fleet?” 

Scrubbing technologies are generally categorized as either wet or dry systems. There is 

essentially one option for the dry system whereas the wet system has at least three variants. 

Each of the wet and dry options will be described in this section to provide a sense of their 

relative merits. 

Appendix A of this Guide provides an extensive survey of the available scrubbers. Please 

use this survey to perform comparisons between systems in terms of technology approach 

and physical plant integration. This section discusses the various technologies in general 

terms. 

4.1 Wet Systems 

A wet scrubbing system is one which uses either untreated seawater or treated freshwater as 

the scrubbing agent to remove SOx and particulate matter from exhaust gas. The water 

undergoes some form of filtration or chemical treatment before being discharged overboard 

or re-circulated to the system. Wet systems may be categorized as open loop, closed loop, 

or hybrid. Specific functional differences between the three variants are outlined below. 

4.1.1 Open Loop System 

An open loop system relies exclusively on ambient seawater for exhaust gas scrubbing. The 

term ‘open loop’ is used because 100% of the water drawn in from the sea is discharged 

after passing through the system. The process relies on the natural alkalinity of seawater to 

facilitate scrubbing of the sulfur oxides. 

In this process seawater is drawn from below the waterline and pumped to a scrubber 

located in the engine exhaust uptake. The scrubber is a passive device that puts the water in 

direct contact with the exhaust gas. Internal baffles divide the scrubber into several stages; 

each stage causing different interactions between the gas and water. Seawater is injected 

near the top through special nozzles and gravitates to the bottom passing through the various 

stages. 

Upon leaving the scrubber the water (now termed wash water) must be processed before 

discharge to the sea. Wash water is either pumped or drained via gravity to a cyclonic 

separator; another passive device which relies on internal baffles to induce fluid rotation. 

This rotation causes centrifugal separation of the heavy suspended particulates from the 

water. The particles, mostly silt from the ambient seawater, are drained away as sludge 

while the water is allowed to continue through the process. 

A secondary stream of seawater which has bypassed the entire scrubbing process is mixed in 

equal parts with the water leaving the cyclonic separator. This mixing effectively dilutes the 

wash water bringing the pH to a level that is acceptable for overboard discharge in most 

areas. 
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Selection Guide, Revision A File No. 10047.01, 22 February 2011 

Figure 1. Open Loop System (Hamworthy Krystallon) 

Advantages of the open loop system include the following:

 The process requires no hazardous chemicals; seawater is the only scrubbing agent. 

 The system has fewer components than other wet systems. 

Disadvantages of the open loop system include the following: 

 Operation in brackish or fresh water or in high water temperatures can inhibit 

scrubbing of SOx. 

 The discharge of effluent with acidic pH may be restricted in some regions, thereby 

requiring a switchover to low sulfur fuel or an alternative scrubbing system. 

4.1.2 Closed Loop System 

A closed loop system uses fresh water that is chemically treated to effect scrubbing. The 

term ‘closed loop’ is used because most of the scrubbing agent is re-circulated with only 

minimal water intake and effluent discharge. Chemical dosing is added at the rate needed to 

neutralize SOx in the exhaust gas. 

Fresh water that has been dosed with sodium hydroxide solution is pumped from a holding 

reservoir to a scrubber. The scrubber operates in the same manner as that used in open loop 

systems; putting exhaust in direct contact with the fluid. After scrubbing the water is 
Exhaust Gas Cleaning Systems 22 The Glosten Associates, Inc 

Selection Guide, Revision A File No. 10047.01, 22 February 2011 

drained back to the reservoir. A seawater / freshwater heat exchanger extracts heat from the 

closed fresh water loop, the seawater being supplied by an independent SW pump. 

As this process repeats the chemical reaction between the Sodium Hydroxide and the SOx 

depletes the reserves of NaOH in the solution. A dosing unit injects NaOH at the rate 

necessary to maintain a constant pH at the scrubber outlet. To purge the benign products of 

reaction (sulfates) a small flow of water is constantly drained from the reservoir. At the 

same time make-up water from the ship’s fresh or potable water system is added to maintain 

the same volume in the reservoir. The drained water is sent to a treatment unit for 

processing. 

The treatment unit is a mechanized centrifugal separator similar to those employed in fuel 

oil and lube oil systems. The separator extracts the heavy particulates and discharges clean 

water as effluent. The effluent is discharged in relatively small volumes (compared to open 

loop systems) and may be sent to a holding tank to avoid discharging in port. 

Figure 2. Closed Loop System (Wärtsilä) 

Advantages of the closed loop system include the following:

 The system can operate in all regions regardless of seawater alkalinity or 

temperature. 

 Effluent may be stored on board for whatever duration the tank volumes will permit. 

Disadvantages of the open loop system include the following: 

 The system has more components than an open loop system. 
Exhaust Gas Cleaning Systems 23 The Glosten Associates, Inc 

Selection Guide, Revision A File No. 10047.01, 22 February 2011 

 The system requires a constant supply of sodium hydroxide solution, a hazardous 

substance requiring special handling, care, and cost. In addition, the use of caustic 

chemicals increases the effort to gain regulatory approval. 

4.1.3 Hybrid System 

A hybrid system capitalizes on the advantages of the open and closed loop systems. The 

system largely resembles a closed loop system but incorporates additional components 

which allow it to operate as either an open or closed loop system. The intent is that the 

system can operate as an open loop system at sea to conserve chemical agent or operate as a 

closed loop system in port to avoid issues stemming from water quality or port discharge 

regulations. 

The hybrid system has all of the same components that are present in the closed loop system, 

with the primary distinction being the presence of two wash water treatment devices. 

Because the open loop mode of operation requires 100% of the water to undergo centrifugal 

separation it is therefore necessary to have a secondary device large enough for the higher 

flow rate. 

To change from the closed loop mode to the open loop mode requires a change in the 

functions of certain components. 

 The seawater pump used to provide cooling water to the heat exchanger in closed 

loop mode becomes the supplier of dilution water in the open loop mode. The heat 

exchanger is bypassed in open loop mode. 

 The pump used to circulate fresh water in closed loop mode becomes the source of 

seawater for the scrubber in open loop mode. 

The change in modes requires change-over from the small volume centrifuge to the large 

volume cyclone separator. Otherwise, system operation is the same as described in the 

above sections. 

The same advantages and disadvantages described above are applicable to this system. 

There is an additional disadvantage in that the system requires the most components of any 

wet option. 
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Selection Guide, Revision A File No. 10047.01, 22 February 2011 

Figure 3. Hybrid System (Aalborg Industries) 

4.1.4 Wet Systems Claiming NOx and CO2 Reductions 

New variants of the wet scrubber system have begun to emerge with claims of significant 

NOx and CO2 reductions. Ecospec Marine of Singapore is claiming significant reductions 

in NOx and CO2 emissions with their CSNOx system while Simulation Tech, Inc. (STI) of 

South Korea is claiming significant reductions in CO2 emissions in their wet scrubber units. 

The CSNOx system claims: “Meet 0.1 % low sulfur fuel emission criteria. No need to use 

distillate or modify the fuel system to accommodate the use of distillate. Meet NOx Tier 1, 

2 and 3 requirements. Surpass all present international GHG mitigation targets.” (MEPC 60 

Presentation.) Compliance with IMO wash water requirements is also claimed. 

The CSNOx first stage scrubber is effectively an open loop wet scrubber with similar wash 

water handling techniques. A second stage scrubber uses seawater that has been specially 

conditioned by “ultra low frequency” waves that results in alkaline seawater that reportedly 

absorbs the remaining SOx as well as NOx and CO2. The NOx is reported by Ecospec to 

convert to nitrogen gas, relieving concern of exceeding nitrogen limits in the seawater. The 

CO2 is reported to permanently convert into bicarbonate 

The CSNOx is continuing to undergo verification testing on the motor tanker White Star. 

ABS has confirmed measurements taken validating reductions under some load conditions 

in the first of three planned pilot project tests. If full scale testing proves to be as effective 

as the initial claims this would truly be a remarkable technology. Without further empirical 

evidence, it would be premature for Owners to commit to this solution. 
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Selection Guide, Revision A File No. 10047.01, 22 February 2011 

Figure 4. Pilot Scale Ecospec Installation 

4.2 Dry Systems 

Dry exhaust scrubbing systems are so described because they rely primarily on dry bulk 

reactants for treatment of the exhaust gas. The process utilizes calcium hydroxide in the 

form of spherical pellets. The pellets are loaded on the ship and stored in bulk. When the 

system is in use the pellets are fed via belt conveyor to a dry reactor or ‘absorber’ through 

which the engine exhaust passes. The SOx react chemically with the pellets to produce 

gypsum (CaSO4) and water. The gypsum is removed from the bottom of the absorber by a 

discharge conveyor and captured for storage and subsequent offloading. 
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Selection Guide, Revision A File No. 10047.01, 22 February 2011 

The gas travels from the absorber to an SCR reactor where NOx is chemically removed from 

the gas with the injection of ammonia or urea. A large volume blower on the outlet of the 

SCR reactor pulls the gas through the system, thereby reducing the back pressure at the 

engine exhaust outlet. 

Advantages of the dry system include the following:

 The system does not produce any liquid effluent for overboard discharge. 

 The system can reduce NOx emissions. 

Disadvantages of the dry system include the following: 

 The ship must have suitable storage and handling arrangements to accommodate the 

dry bulk reactants and products, as well as a reliable supply of materials. 

 Increased costs from use of urea for NOx abatement, and calcium hydroxide for SOx 

abatement. 

Figure 5. Dry System (Couple Systems) 

4.3 Fuel Switching 

Fuel switching to low sulfur fuel oil distillates when entering port has been practiced for 

decades by vessels calling in California waters. When the ship reaches a specified distance 

from an emissions control area (ECA), it initiates the process of switching from burning 

high sulfur fuel oil to burning low sulfur fuel oil. The duration of the switchover typically 

takes about one hour, depending on system component size and fuel burn rate. Technical 

Considerations of Fuel Switching Practices was published on 3 June 2009, by the API 

Technical Issues Workgroup and the ABS Fuel Switching Advisory Notice, both of which 

provide guidance on the below topics related to propulsion shutdown issues such as: 
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Selection Guide, Revision A File No. 10047.01, 22 February 2011 

 Sticking/scuffing of fuel injection components as a result of the 

o thermal shock or reduced viscosity and lubricity, and 

o incompatibility of fuels being switched (complete fuel pump seizure). 

 Mismatched crankcase or cylinder lubrication oil resulting in accelerated piston/liner 

wear. 

 Liner lacquering resulting in difficulties maintaining oil film thickness. 

These risks can be mitigated by a combination of the installation of special equipment and 

the modification of operational procedures. The extent and nature of conversion required 

for a vessel will be determined by the type of equipment installed on the vessel, and the 

arrangement of the affected systems. For vessels not already outfitted with special fuel 

switching equipment, modification costs will generally range from $15K to $80K. This 

assumes that the vessel has the appropriate tank capacity to carry the two fuel types. 
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Selection Guide, Revision A File No. 10047.01, 22 February 2011 

Section 5 Integration, Operations, and 

Maintenance Practicality 

“Can an EGCS be practically integrated with ship operations?” 

Installation of an EGCS will place additional demands on those responsible for plant 

operation and maintenance. The decision to install an EGCS should consider the additional 

manpower required to sustain operation. Depending on a ship’s current operations and 

maintenance profile, installation of an EGCS may require additional crew. This section will 

outline the major sources of additional labor associated with each type of system. 

At this time there is insufficient empirical data from which to derive actual operating and 

maintenance data. In order to quantify the manpower requirements of an EGCS system a 

comparison shall be drawn between each major EGCS component and more common 

(existing) shipboard equipment of similar complexity. 

What follows are discussions (grouped by system) identifying the general complexity and 

manpower requirements of each component. 

5.1 Physical Integration Challenges – All Systems 

The installation of exhaust gas cleaning systems (EGCS) present integration challenges to 

new builds and retrofits alike. Appendix A provides summary information of several EGCS 

including footprints, weights, and backpressures. This will provide each operator a baseline 

on which to begin discussions with suppliers on integration. Key considerations include: 

 Weight and stability. Weights will vary significantly by scrubber rating and type. 

The primary weights of concern are the scrubbers themselves as they are positioned 

high and even a 20 ton wet weight could be of significant concern for ships that have 

limited remaining stability margin. 

 Water handling systems. These systems can be significant for any of the wet 

systems, but particularly for open loop and hybrid systems. For example, a 50 

megawatt plant with an open loop scrubber will require 4,500 cubic meters an hour 

of wash water. This wash water would require about 0.5 megawatts of power to run, 

and a 760 mm pipe (30 inch diameter). 

 Machinery and stack arrangements. In the case of new builds, the EGCS will 

become a primary component for arrangements and weight allowances. For retrofits, 

fitting this equipment into existing spaces will be a significant challenge and in some 

cases may require installation of the scrubber unit in the weather or new above the 

main deck enclosure. 

 Exhaust backpressure. Most engines can tolerate ~3.0 kPa of backpressure (12 

inches of water) without significant degradation of power or adverse affects. 

Exceeding the allowance will degrade performance by ~ one percent for each 

additional 3 kPa of backpressure. It should be noted that exhaust piping and 

silencers may required, depending on the scrubber design. If one is required, then 

backpressure allowances should be included. 

 Electrical power. The demands of these systems can be significant reaching 2% of 

nominal power, potentially requiring additional generating capacity. 
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Selection Guide, Revision A File No. 10047.01, 22 February 2011 

 Failure modes. Being integral to diesel engine operations, a failure modes and 

effects or other analysis should be conducted to assure that a scrubber failure will not 

result in loss of ships service or propulsion power. 

5.2 Open Loop Seawater System 

Scrubber: The scrubber is a passive device that relies on the hydraulic pressure of an 

external supply pump for proper operation. Internally the scrubber is divided into multiple 

sections for processing of the exhaust gas. There are few, if any, moving parts although 

internal bypass dampers may be included. Regular inspection, de-fouling, and operational 

checks are required. Internal filtration elements in the scrubber will require periodic 

replacement. The scrubbers are similar in size and service profile to exhaust gas 

economizers. The Owner should anticipate a maintenance profile similar to inert gas system 

scrubbers commonly found on tank ships. 

Pumps and Strainers: Strainers and centrifugal pumps are ubiquitous in shipboard plants. 

The service demands of the external scrubber pumps are essentially the same as those used 

for other auxiliary services such as seawater cooling with the addition of a variable speed 

control drive. The pumping demand is significant with two pumps, each requiring 

approximately 50 m3/hr per engine megawatt. This service profile makes for a predictable 

operation and maintenance schedule. 

Wash Water Treatment Filter: The wash water treatment filter is generally a passive 

filtration assembly relying on fluid velocity and cyclonic baffles to effect centrifugal 

separation of sludge. With no moving parts or consumable elements the device would only 

require periodic inspection and de-fouling. 

Sludge Handling: Sludge that is separated out in the Wash Water Treatment Filter must be 

retained on board and periodically discharged to a shoreside reception facility. The sludge 

may be retained in existing shipboard sludge tanks, but the pump-out interval will decrease 

requiring more frequent sludge transfers. Existing reports on scrubber sludge indicates that 

it is not hazardous, and therefore does not need to meet IMO Annex I handling 

requirements. However, Annex VI does not allow incineration of EGCS sludge. 

Effluent Monitoring: Instrumentation used to monitor effluent conditions will require 

periodic calibration, inspection, and possible element replacement. The monitoring of 

turbidity is a common function of oil content monitors used in shipboard oily water 

separators. It is reasonable to expect that the degree of intervention required will be similar 

for the scrubber effluent instrumentation. Scrubber monitoring will however be continuous 

and requires monitoring of at least three parameters, in comparison to oil content monitor of 

a single parameter performed only periodically. 

Exhaust Gas Monitoring: The instrumentation used for monitoring of scrubbed exhaust 

gas is not unlike that used in tank vessel inert gas monitoring. Scrubber monitoring however 

will be continuous as per regulation, and requires monitoring of more difficult parameters 

such as SO2. The Owner should anticipate the need for periodic calibration, servicing of 

calibration gases, inspection, and possible element replacement. Type Approval processes 

for this equipment will be required for Scheme B, including third party calibrations and 

maintenance, are anticipated. 
Exhaust Gas Cleaning Systems 30 The Glosten Associates, Inc 

Selection Guide, Revision A File No. 10047.01, 22 February 2011 

Controls: The controls for an open loop system should not impose any significant 

operational or maintenance costs. Modern PLC/microprocessor controls are robust and 

generally do not require any attention beyond periodic inspection and testing of the power 

supplies. 

5.3 Closed Loop Freshwater System 

Buffer Tank: The buffer tank is a passive device, acting simply as a reservoir where the 

solution is allowed to stabilize. The tank has no internal moving parts and, besides periodic 

inspection, would require little or no operator intervention. 

SW/FW Heat Exchanger: The SW/FW heat exchanger is required to remove heat that is 

absorbed by the solution as it passes through the scrubber. Although this is a passive device 

the Owner should anticipate the need for regular disassembly and cleaning of both FW and 

SW sides of the heat transfer surfaces. 

Pumps and Strainers: The SW and FW circulation pumps will experience the same 

operational demands as those present in the open loop system. Again, this represents a 

predictable addition to the ship’s maintenance workload.

Sodium Hydroxide Unit: The NaOH unit is used for storage and dosing. Generally it is a 

passive device and should require little operator intervention. However, the loading of the 

alkaline solution is a critical operation that requires diligence and strict adherence to safety 

procedures. Due to the hazardous nature of the chemical Owners should plan for a tightly 

controlled evolution requiring several crew members to remain present and fully attentive 

during a transfer. This procedure would take place at regular intervals during port stops and 

is a significant addition to the list of duties assumed by the ship’s crew. 

Water Treatment Device: The water treatment device is a mechanized centrifugal 

separator similar to those commonly used for fuel oil or lube oil processing. An owner 

should expect at least the same degree of operator intervention; regular operational checks 

and moderate to frequent disassembly and cleaning. 

The system contains additional elements which are substantially similar to those found in the 

open loop system. These components include 

 Scrubber 

 Effluent Monitoring Devices 

 Exhaust Gas Monitoring Devices 

 Controls 

 Sludge Handling 

5.4 Hybrid System 

The hybrid system has the ability to operate as an open loop system at sea and operate as a 

closed loop system in port. The system make-up is virtually the same as the closed loop 

system. Through the use of isolation valves, the circulation pumps can serve different roles 

depending on which mode the system is being used in. 

One substantial deviation from the closed loop system is that the hybrid system must have 

two separate wash water treatment devices; one for each mode of operation. The open loop 
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Selection Guide, Revision A File No. 10047.01, 22 February 2011 

mode requires a large device capable of processing 100% of the system flow rate, whereas 

the closed loop treatment device only processes a fraction of the system flow rate. 

5.5 Dry System 

Absorber: The absorber (sometimes called the reactor) is the primary component involved 

in the dry scrubbing process. It is a large assembly mounted in the exhaust uptake which 

funnels the hot exhaust gas through a bed of calcium hydroxide pellets. The gas comes in 

direct contact with the pellets causing a chemical reaction which removes entrained SOx. 

The device is passive relying on external conveyors to feed unspent pellets and remove 

spent pellets. The absence of moving parts makes the device relatively easy to maintain, but 

periodic inspections of the internals should be conducted. 

Conveyors: Conveyance of the dry chemical reactants and by-products to and from the 

absorber is accomplished with mechanical conveyor belts. These would be similar to those 

used in bulk ship cargo handling and would require frequent inspection and planned 

maintenance of the rotating elements and belts. 

SCR Reactor: The selective catalytic reduction (SCR) reactor is the component where 

NOx are removed from the exhaust gas via chemical reaction with an injected chemical. A 

liquid reactant such as ammonia or urea is injected and mixed into the exhaust stream 

thereby reacting with the NOx and precipitating benign by-products. The reactor itself has 

no moving parts but it is reliant on external pumping and chemical storage devices. 

Exhaust Gas Blower: A large volume blower is used to pull treated exhaust gas from the 

outlet of the absorber. As with similar large blowers (e.g. IG system blowers, forced draft 

fans) the device will require regular operational checks and moderate maintenance tasks. 

Isolation and Bypass Dampers: The dampers used to divert the flow of exhaust gas 

through or around the absorber are essentially large butterfly valves designed for service in 

high temperature applications. Such dampers prevail in tankship IG systems for gas 

isolation. Periodic maintenance of seals and damper actuators will be required. 

Calcium Hydroxide Storage: A closed, dry storage hopper is used as a reservoir for the 

unspent calcium hydroxide pellets. The hopper itself requires little or no attention from the 

ship’s crew, but regular dry bulk loading operations must be carried out and supervised. It is 

improbable that all shoreside terminals will have the necessary handling equipment for 

loading the product in bulk. Therefore the Owner should plan for the contingency that the 

bulk products may need to be loaded in packaged form and transferred (internally) by the 

ship’s crew to the hopper. Depending on the intervals between loading and the volumes 

being loaded this evolution could require significant manpower if performed as described. 

Hydraulic cranes or similar means must be added to the vessel if they are not already 

installed. 

Gypsum Storage: As with the calcium hydroxide pellets, the reaction byproduct gypsum 

must be retained on board and discharged at regular intervals. A similar challenge is faced 

in the respect that not all shoreside terminals will have equipment or reception facilities that 

can easily remove the spent pellets en masse. Possible ship-based solutions include the 

following: 
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Selection Guide, Revision A File No. 10047.01, 22 February 2011 

 Compressed air ‘blow tanks’ similar to those used for transferring bulk drilling mud 

in offshore supply vessel applications. This requires a large pressure vessel tank and 

dedicated air compressor(s) to effect dry bulk transfer. It also requires a shore side 

facility that can accept large flow rates of dry bulk material through a pipeline. 

 Manual option; essentially the reverse of the loading option described above. This 

would require that the vessel have on-board portable containers which can be filled 

by the crew at the base of the gypsum storage hopper. Portable containers then 

removed by crane or hoist. 

The system contains additional elements which are substantially similar to those found in the 

wet systems. These components include 

 Exhaust Gas Monitoring Devices 

 Controls 

5.6 Summary 

The following tables compare the components for each type of system to the conventional or 

existing shipboard equipment items. 

The addition of any type of EGCS will increase the workload for shipboard engineering 

personnel. The ability of a ship’s crew to absorb this increase in workload is dependent on 

the current manning levels and utilization. These factors are in many ways linked to the ship 

type. 

For instance, the engineering plant on board an ocean-going containership is less complex 

than the plant on board a tank vessel. A tank vessel carrying oil or chemicals has on-board 

cargo pumping and inert gas systems which do not exist on dry cargo ships, and which 

require constant supervision during cargo operations. Therefore, it is possible that the 

engineering department on a dry cargo ship may be capable of absorbing the additional 

workload without an increase in manning. 

The ship type also carries with it certain regulatory barriers which may further limit a crew’s 

ability to carry the additional workload. Crews on board U.S. registered tank ships are 

limited by OPA 90 regulations to work no more than 12 hours in a 24 hour period. It would 

not be possible for an Owner to simply make the crew work longer days to compensate for 

the increase in workload. 

In summary, the table and discussions are intended to give the reader a general sense of how 

much burden an EGCS will introduce. Ultimately, the Owner must weigh this information 

against known variables such as ship type, crew utilization, and watch-keeping regulations. 

A prudent approach may be to start operations with an additional crew member specifically 

trained to operate the EGCS, and subsequently shift these burdens to other crew members as 

possible. 
Exhaust Gas Cleaning Systems 33 

Selection Guide, Revision A FilTable 15. Comparison Chart for Open Loop, Closed Loop, and Hybrid Wet Systems 
Exhaust Gas Cleaning Systems 34 

Selection Guide, Revision A FilTable 16. Comparison Chart for Dry Systems 

No Marine 

Comparison

Dry Bulk 

Conveyor

No Marine 

Comparison

Inert Gas System 

Blower

Inert Gas System 

Damper

IG Monitoring 

Instrumentation

Dry System Components

Absorber



Feed Conveyor



Extraction Conveyor



SCR Reactor



Exhaust Gas Blower



Bypass Damper



Inlet Isolation Damper



Outlet Isolation Damper



Exhaust Monitoring Instrumentation



Control ModuleCalcium Hydroxide StorageGypsum Storage

Conventional or Existing Shipboard Equipment
Exhaust Gas Cleaning Systems 35 The Glosten Associates, Inc 

Selection Guide, Revision A File No. 10047.01, 22 February 2011 

Section 6 Discussion 

The ship operator considering an exhaust gas cleaning system (EGCS) faces a conflicting 

pair of recommendations. On the one hand, the fuel cost savings for those operating within 

an emissions control area (ECA) is so substantial that an EGCS may be a competitive 

necessity. On the other hand, installations are discouraged because the technology is not yet 

fully mature, places a significant burden on ship arrangements and operations, and raises 

some environmental impact concerns. This section provides a discussion on these 

considerations. 

6.1 Cost Advantage 

The cost advantage for EGCS is a combination of quantity of fuel burned within an ECA 

and the cost differential between the high-sulfur and low-sulfur fuel. The analysis in this 

Guide indicates that starting in 2015, ships that burn at least 4,000 metric tons of fuel oil 

annually within an ECA should consider an EGCS. 

A key break point in fuel cost differentials is when sulfur limits become so low, that they 

cannot be practically or cost-effectively achieved by removing sulfur from residual fuel. 

Such limits, generally 0.5% sulfur or lower, require high-cost distillate fuel oil or 

alternatives such as EGCS or natural gas. The potential cost savings for an EGCS is then 

the differential between the high-cost distillate and the low-cost residual fuel oil. 

Such differentials are currently in effect in EU ports and California coast waters that limit 

fuel sulfur concentrations to 0.1% sulfur. The cost advantage becomes widespread in 2015 

when IMO enacted ECAs will require the 0.1% sulfur emissions. When worldwide sulfur 

limits reach 0.5% in either 2020 or 2025 the cost savings opportunity extends to ships 

regardless of their operating area. 

Over the last eight years residual fuel has cost roughly 50% less than distillate fuel. On 10 

January 2011, the cost differential between MGO and IFO380 in Los Angeles was about 

$250 per metric ton (bunkerworld.com). It is difficult to predict how this differential will 

change over time. The cases analyzed in this Guide assume that the percentage differential 

will remain constant, and that fuel cost escalation will average 8% annually over the 

assumed ten-year life-cycle period. Based on these assumptions, net present values between 

$4.8M and $20M, and internal rates of return between 20% and 53% are calculated. Ship 

operators are encouraged to utilize their own fuel cost differential predictions, as the 

analysis is very sensitive to fuel cost escalations. 

6.2 Ship Impacts 

The impact of an EGCS on ship arrangements, operations, and logistics is both broad and 

pervasive. The machinery is very large, impacts key mechanical, electrical, and control 

systems, and in the case of chemical based systems requires impacts logistics for bunkering 

and safety response. 

In spite of these challenges, the cost savings potential remains significantly high. The ship 

operator installing an EGCS will need to return some of that cost savings to ensure success 

operations. An EGCS will require a significant investment to ensure adequate installation 
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Selection Guide, Revision A File No. 10047.01, 22 February 2011

and commissioning, ongoing technical support, initial and ongoing training, and most likely 

an increase in shipboard engineering staff. Without this commitment of resources, 

installation of an EGCS is not recommended. 

6.3 Applicability to non-Ocean Going Vessels 

Exhaust gas cleaning systems offer significant benefits to non-ocean going vessels in terms 

of abating PM, NOx, and hydrocarbons. Equipment focused on these pollutants may be 

significantly smaller than sulfur focused scrubbers, and therefore may more readily fit onto 

smaller vessels. However, this Guide focuses on the removal of sulfur from residual fuel. 

The employment of exhaust gas cleaning systems for sulfur abatement on smaller marine 

vessels, non-Ocean Going Vessels, faces several challenges: machinery spaces may be too 

restricted to fit the large scrubber plants; many already burn high cost marine diesel oil 

(MDO) or marine gas oil (MGO) eliminating much of the potential fuel cost savings; those 

that burn residual fuel oil may not burn enough to gain adequate pay-back on the capital 

investment. 

Many smaller marine vessels, such as ocean going tugs or supply boats, have large 

propulsion plants tightly fit into relatively small machinery spaces. These service vessels 

are often designed around the propulsion plant, and therefore often have no additional space 

for even moderate increases in equipment. One solution for some vessels will be to locate 

the scrubbing equipment in the weather or in a new deck house. For small vessels, often all 

exterior spaces are working areas essential to the vessel’s mission. A review of the available 

area in comparison to the machinery footprints provided in the appendix of this Guide will 

assist the operator with an initial evaluation. 

The cost advantages of sulfur focused EGCS are dependent on the fuel cost differential 

between high-sulfur residual fuel oil and low-sulfur distillate fuel oil. In general, this means 

ocean going vessels that run slow speed diesel engines. There are classes of marine vessels, 

such as anchor handling tugs or larger ferries, that burn residual fuel oil in medium speed 

diesel engines. In these cases, the fuel has a high fuel cost differential but may not be in 

significant quantity to justify the equipment expenses. This Guide suggests 4,000 metric 

tons of fuel oil burned annually within an ECA as a point where an operator should develop 

an economic analysis. 

There are many vessels that burn MDO, a blend of mostly distillate with some residual fuel 

oil. MDO may be burned out of convenience to avoid heavy fuel oil handling efforts, or 

because the associated engine is not capable of handling the residual fuel oil. However, the 

fuel cost differential between the MDO and 0.1% distillate fuel oil does not provide 

adequate increase in cost to shift the advantage to EGCS installation. For example, the 

Houston price for marine gas oil (most similar to 0.1% sulfur distillate) was only $47.50 

more per metric ton than the cost of MDO at $823.50 (bunkerworld.com 11 February 2011). 

6.4 Environmental Regulations 

EGCS supplied data indicates that the wash water from open-loop style scrubbers is 

acceptable for discharge into ambient waters in accordance with international wash water 

guidelines, as well as the United States EPA Vessel General Permit requirements. However, 

ship operators should be cautioned that the regulation of ship discharges, particularly in the 
Exhaust Gas Cleaning Systems 37 The Glosten Associates, Inc 

Selection Guide, Revision A File No. 10047.01, 22 February 2011

United States, is subject to uncertainty. For example, several U.S. states have developed 

ballast water discharge requirements that conflict with international and federal 

requirements. 

Sulfur regulations were initially developed as fuel standards, as the sulfur is not consumed in 

the combustion process, but rather passes into the air emissions. The EGCS alternative was 

accepted under the assumption that it would provide a similar level of emissions reductions. 

However, the sulfur-based fuel standard included an expectation that a significant reduction 

in particulate matter emissions would also occur. This expectation is not part of either the 

fuel standards, or the EGCS requirements. This creates uncertainty, as requirements for 

particulate matter reductions may be included in future EGCS requirements. 

It is not clear whether a ship with an EGCS failure will be permitted to continue operations. 

This will require further analysis and discussion with regulatory authorities as the system 

installations become more widely implemented. One strategy for the ship operator would be 

to include an ability to switch-over the low-sulfur diesel fuel in these instances. 

Alternatively, the ship operator might consider installation approaches that prevent single 

point failures from impacting propulsion and/or generating capacities. 

6.5 Experience Matters 

As with any new or developing technology, the ship operator should proceed with caution. 

The most experienced EGCS suppliers have only a handful of shipboard installations, and 

most only have a single pilot project. Successful selection, integration design, installation, 

and commissioning of an EGCS will require careful consideration and significant effort. 

The ship operator should expect that an EGCS installation will require ongoing support, and 

potential upgrades, particularly for early installations. As such, the relationship with the 

supplier and confidence in continued support are important factors when selecting a system. 

 
Exhaust Gas Cleaning Systems 38 The Glosten Associates, Inc 

Selection Guide, Revision A File No. 10047.01, 22 February 2011

Section 7 References 

Reference 1 Corbett, J.; Wang, C.; Winebrake, J.; Green, E.; “Allocation and 

Forecasting of Global Ship Emissions,” Clean Air Task Force, Boston, 

11 January 2007. 

Reference 2 Hoy-Petersen, N.C.; “An EGCS conceived by Shipowners for 

Shipowners,” Clean Marine AS, December 2010. 

Reference 3 “An Estimate of Operating Costs for Bulk, Ro-ro and Container Ships,” 

Bureau of Transport Economics (BTE), September 1982. 

Reference 4 “Assumptions to the Annual Energy Outlook,” Energy Information 

Administration, March 2009. 

Reference 5 Behrends, B.; Liebeseit, G.; “A Theoretical Environmental Impact 

Assessment of the Use of a Seawater Scrubber to Reduce SOx and NOx 

Emissions from Ships,” Research Centre Terramare, Wilhelmshaven, 

Germany. 

Reference 6 “Avoiding propulsion loss from fuel switching: American Petroleum 

Institute Technical Considerations,” Marine Safety Alert, United States 

Coast Guard, Washington DC, 16 June 2009. 

Reference 7 “Basic Principles of Ship Propulsion,” MAN B&W Diesel A/S, 

Copenhagen, Denmark. 

Reference 8 “Bunker Fuel Charges Fact Sheet,” TSA Carriers Organization, 

http://www.tsacarriers.org/fs bunker.html, 8 December 2010. 

Reference 9 Hayman, S.; “California Low Sulfur Fuel Requirements: Exhaust Gas 

Scrubbers?” California Air Resource Board, email 17 November 2010. 

Reference 10 “California Ocean Plan,” California Environmental Protection Agency 

State Water Resources Control Board, 2005. 

Reference 11 “California Ocean Plan,” California Environmental Protection Agency 

State Water Resources Control Board, 2001. 

Reference 12 “Caustic Soda Prices and Pricing Information,” ICIS.com, July 2009. 

Reference 13 “China-U.S. Transpacific Route and Sailing Schedule,” Horizon Lines, 

www.horizonlines.com, November 2010. 

Reference 14 Zoeteman, Peter; “Closing the Loop, Exhaust Cleaning Systems,” 

bunkerspot, August/September 2010. 

Reference 15 “Containership Propulsion – beyond Post-Panamax,” MAN B&W Diesel 

A/S, Copenhagen, Denmark. 
Exhaust Gas Cleaning Systems 39 The Glosten Associates, Inc 

Selection Guide, Revision A File No. 10047.01, 22 February 2011

Reference 16 “Control of Emissions from New Marine Compression-Ignition Engines 

at or Above 30 Liters per Cylinder,” Proposed Rule, 40 CFR Parts 9 and 

94, Environmental Protection Agency, 7 December 2007. 

Reference 17 “Control of Emissions from New Marine Compression-Ignition Engines 

at or Above 30 Liters per Cylinder,” Proposed Rule Preamble, 40 CFR 

80, 85, 86, et al., Environmental Protection Agency, 26 June 2009. 

Reference 18 “Control of Emissions from New Marine Compression-Ignition Engines 

at or Above 30 Liters per Cylinder,” Final Rule, 40 CFR Parts 80, 85, 86, 

et al., Environmental Protection Agency, 30 April 2010. 

Reference 19 “Cost Savings & Increased Profit,” On-Board Emissions Monitoring, 

MariNOx, 11 January 2007. 

Reference 20 “CSNOx Greenhouse Gas Abatement Technology: Update of CSNOx 

performance on Singapore registered ship,” Ecospec, January 2010. 

Reference 21 “Distances Between United States Ports,” United States Department of 

Commerce, National Oceanic and Atmospheric Administration (NOAA), 

and National Ocean Service, 10th Edition, 2009. 

Reference 22 Toombs, P.; “Emission Regulations & The Impact of Exhaust Gas 

Cleaning System Technology,” Marine Exhaust Solutions, May 2010. 

Reference 23 “Evaluation of Low Sulfur Marine Fuel Availability – Pacific Rim,” 

Starcrest Consulting Group, LLC, July 2005. 

Reference 24 “Exhaust Gas Cleaning, Aalborg,” Olav Knudsen, Aalborg Industries, 

July 2010. 

Reference 25 Marttinen, V.; “Feasible SOx Solutions,” Wärtsilä’s Environmental 

Seminar in Helsinki, 22 June 2010. 

Reference 26 Filancia, A.; “Reducing Emissions from Shipping: Wärtsilä’s 

Solutions,” Version 9.0, Wärtsilä. 

Reference 27 van Rhynbach, E.; Briers, K.; “Fuel Storage & Handling Systems and the 

Costs of Operating in ECA’s,” Herbert Engineering, presentation, 

Society of Naval Architects & Marine Engineers Symposium, Operating 

Ships within Emission Control Areas (ECA’s), San Francisco, California, 

28-29 April, 2010. 

Reference 28 “Fuel Switching Advisory Notice,” ABS, March 2010. 

Reference 29 “Global Trade and Fuels Assessment – Future Trends and Effects of 

Requiring Clean Fuels in the Marine Sector,” Environmental Protection 

Agency, November 2008. 

Reference 30 “Guide to Marine Emissions Control,” Simulation Tech, Inc., 2010. 
Exhaust Gas Cleaning Systems 40 The Glosten Associates, Inc 

Selection Guide, Revision A File No. 10047.01, 22 February 2011

Reference 31 “Guidelines for Exhaust Gas Cleaning Systems,” IMO, Marine 

Environment Protection Committee, Resolution MEPC.170(57), 57/21, 

Annex 4, 4 April 2008. 

Reference 32 “Guidelines for On-Board Exhaust Gas-SOx Cleaning Systems,” IMO, 

Marine Environment Protection Committee, 53/24/Add.1, Annex 12, 22 

July 2005. 

Reference 33 Hansen, O.; Jacobsson, J.; Jamttjam, J.; Cooper, D.; Flodstrom, E.; “The 

Demo Project,” PriceWaterhouseCoopers and The Swedish 

Environmental Research Institute, Stockholm, 22 April 2005. 

Reference 34 Henriksson, T.; “SOx scrubbing of marine exhaust gases,” Wartsila 

Technical Journal, February 2007. 

Reference 35 “Holland America Line/Krystallon Sea Water Scrubber Technology 

Demonstration Project,” Presentation, Holland America Line Web Site, 

22 December 2008. 

Reference 36 Hoy-Petersen, Nils; “EGCS Conceived by Shipowners by Shipowners,” 

Clean Marine AS, 2010. 

Reference 37 “Low Sulfur Fuel: Impacts on the Marine Industry, ExxonMobile 

Marine Lubricants,” June 2009. 

Reference 38 “Low-Sulfur Marine Fuel Availability Study,” Port of Long Beach and 

Port of Los Angeles, 14 April 2008. 

Reference 39 “Marine Exhaust Gas Scrubber, MEPC Correspondence Group on Wash 

Water Discharge Criteria,” The European Association of Internal 

Combustion Engine Manufacturers, 29 March 2007. 

Reference 40 “Marine Project Guide-Wartsila 20,” Wartsila, January 2004. 

Reference 41 “Marine Scrubbing by BELCO®,” Dupont, 2010. 

Reference 42 Marttinen, Vesa, “Feasible SOx Solutions,” Wärtsilä’s Environmental 

Seminar, Helsinki, June 2010. 

Reference 43 “Notes on Heavy Fuel Oil,” ABS, 1984. 

Reference 44 “Prevention of Air Pollution from Ships, Advice by GESAMP on the 

interim criteria for discharge of washwater from Exhaust Gas Cleaning 

Systems for removal of sulphur-oxides,” IMO, Marine Environment 

Protection Committee, 59/4/19, 59th Session, Agenda Item 4, 8 May 

2009. 
Exhaust Gas Cleaning Systems 41 The Glosten Associates, Inc 

Selection Guide, Revision A File No. 10047.01, 22 February 2011

Reference 45 “Prevention of Air Pollution from Ships, Proposed amendments to 

resolution MEPC.170(57) – Guidelines for Exhaust Gas Cleaning 

Systems,” IMO, Marine Environment Protection Committee, 59/4/31, 

59th Session, Agenda Item 4, 8 May 2009. 

Reference 46 “Prevention of Air Pollution from Ships, Proposed amendments to 

resolution MEPC.170(57) – Guidelines for Exhaust Gas Cleaning 

Systems,” IMO, Marine Environment Protection Committee, 59/10/5, 

59th Session, Agenda Item 10, 10 April 2009. 

Reference 47 “Prevention of Air Pollution from Ships, Proposed draft changes to 

resolution MEPC.130(53),” IMO, Marine Environment Protection 

Committee, 56/4/4, 56th Session, Agenda item 4, 3 May 2007. 

Reference 48 “Prevention of Air Pollution from Ships, Washwater discharge criteria 

for EGCS-SOx units,” IMO, Marine Environment Protection Committee, 

55/4/7, 55th Session, Agenda item 4, 4 August 2006. 

Reference 49 “Proposal of Emission Control Area Designation for Geographic Control 

of Emissions from Ships,” Environmental Protection Agency, April 

2009. 

Reference 50 “Proposed Amendment to Regulations 13 and 14 Implementing the 

Proposed Emission Control Area,” IMO, Marine Environment Protection 

Committee, 59/6/5, Annex 4. 

Reference 51 “Propulsion Trends in Bulk Carriers,” MAN B&W Diesel A/S, 

Copenhagen, Denmark, 22 February 2006. 

Reference 52 “Propulsion Trends in Container Vessels: MAN B&W Two-stroke 

Engines,” MAN B&W Diesel A/S, Copenhagen, Denmark. 

Reference 53 “Propulsion Trends in Tankers,” MAN B&W Diesel A/S, Copenhagen, 

Denmark. 

Reference 54 “Record Fuel Prices Place Stress on Ocean Shipping,” World Shipping 

Council, 2 May 2008. 

Reference 55 “Regulation on Fuel Sulfur and Other Operational Requirements for 

Ocean-Going Vessels within California Waters and 24 Nautical Miles of 

the California Baseline,” CARB Marine Notice 2009-1, 5 May 2009. 

Reference 56 “Regulations for the Prevention of Air Pollution from Ships,” IMO, 

Marine Environment Protection Committee, 58/23/Add 1, Annex 13, 17 

October 2008. 

Reference 57 “Regulatory Announcement: Proposal of Emission Control Area 

Designation for Geographic Control of Emissions from Ships,” 

Environmental Protection Agency, EPA-420-F-09-015, March 2009. 
Exhaust Gas Cleaning Systems 42 The Glosten Associates, Inc 

Selection Guide, Revision A File No. 10047.01, 22 February 2011

Reference 58 “Report of the Marine Environment Protection Committee on its FiftyEighth Session,” IMO, Marine Environment Protection Committee, 

58/32/Add.1, 58th Session, Agenda Item 23, 17 October 2008. 

Reference 59 Karle, I.M.; Turner, D.; “Seawater Scrubbing – reduction of SOx 

emissions from ship exhausts,” The Alliance for Global Sustainability, 

Göteborg, 2007. 

Reference 60 “Scrubbing Technology Update,” Hamworthy Krystallon Presentation, 

SMM Hamburg, 2010. 

Reference 61 Henriksson, T.; “SOx-Scrubbing of Marine Exhaust Gases” Wärtsilä, 

presentation, Exhaust Gas Cleaning Systems Association, Hamburg, 8-9 

September 2010. 

Reference 62 “Summary and Analysis of Comments: Control of Emissions from New 

Marine Compression-Ignition Engines at or Above 30 Liters per 

Cylinder,” United States Environmental Protection Agency, December 

2009. 

Reference 63 “Technical Code on Control of Emission of Nitrogen Oxides from 

Marine Diesel Engines,” IMO, Marine Environment Protection 

Committee, 58/23/Add 1, Annex 14, 17 October 2008. 

Reference 64 “Technical Consideration of Fuel Switching Practices,” API Technical 

Issues Workgroup, 3 June 2009. 

Reference 65 “Tote Orca Class Trailership Fact Sheet,” The General Dynamics 

Corporation/NASSCO, 14 December 2010. 

Reference 66 “Vessel General Permit for Discharge Incidental to the Normal 

Operation of Vessels (VGP),” Environmental Protection Agency and 

National Pollutant Discharge Elimination System, 5 February 2009. 
Exhaust Gas Cleaning Systems, Selection Guide The Glosten Associates, Inc 

Appendix A, Technology Survey, Rev. – File No. 10047.01, 12 January 2011 

Appendix A Exhaust Scrubber Technology Survey 

This Appendix summarizes the Ship Operations Cooperative Program (SOCP) marine 

exhaust gas cleaning system (EGCS) supplier survey results. 

The following information was provided by equipment suppliers, and comprises self-certified 

data on their system particulars and performance. The purpose of this data is to allow SOCP 

members to indentify one or more technologies that may be suitable for their ship(s). 

Members may then contact suppliers directly for detailed integration and commercial 

discussions. 

Response Description 

None Confirms a zero quantity. 

DNA Inquiry does not apply to technology. 

TBD Inquiry either not answered or unclear. 
Exhaust Gas Cleaning Systems, Selection Guide A-1 The Glosten Associates, Inc 

Appendix A, Technology Survey, Rev. – File No. 10047.01, 12 January 2011 

Vendor Summary 

Systems are compared at a high level in the following table. System details are provided on the following 

pages. 

** Vendor Name 

Unit Size* 

Range 

(MW) 

Claimed 

Reductions 

Land-Based 

Installs 

Shipboard 

Installs System Type 

System 

Details 

1 Aalborg Industries 1 to 80 

 99% SOx 

 30-80% PM One: 1 MW One: 21 MW 

Open/Closed 

Loop Hybrid p A-2 

2 

BELCO Clean Air 

Technologies (Dupont) 2 to 200 >97% SOx

Multiple: 

2 to 200 MW None 

Open Loop & 

Closed Loop p A-7 

3 

Cleanmarine, aka The Torrald 

Klaveness Group No response from vendor. 

Couple Systems 1 to 60 

 99% SO2 Multiple: 

4 60% HC 3 to 100 MW One: 3.6 MW Dry EGCS p A-10 

Ecospec/CSNOx 

 99% SO2

One: TBD One: 5 MW 

Open Loop 

System p A-13 

 66% NOx

5 77% CO2

Hamworthy Krystallon 0.5 to 60 

 99% SOx Three: 0.4, 1.0 

& 2.2 MW 

Three: 1.0, 8.5 & 

10 MW 

Open Loop 

6 60% PM System p A-17 

7 Marine Exhaust Solutions 0.3 to 5.6 74-80% SOx DNA 

Nine: Eight at 23 

MW, One 15 MW 

Open Loop 

System p A-21 

8. Wärtsilä Finland Oy 0.68 >99% SOx DNA One: 0.68 MW 

Closed Loop 

System p A-24 

* Unit size refers to diesel engine size served. Boiler units are not considered in this survey. 

** Vendors are listed alphabetically and not by price or efficiency. 
Exhaust Gas Cleaning Systems, Selection Guide A-2 The Glosten Associates, Inc 

Appendix A, Technology Survey, Rev. – File No. 10047.01, 12 January 2011 

Aalborg Industries Exhaust Gas Cleaning B.V., 1 of 5 pages 

Contact René Diks, +3 (0)24 352 3100, rdk@aalborg-industries.com 

Website: www.aalborg-industries.com 

Technology Type(s) EGC system, Combined Open 

Loop (Salt Water) and Closed 

Loop (Fresh Water) 

No Dry Chemical 

Other Products The EGC system can incorporate a 

venturi system (non standard) to 

capture PM up to 80% 

Exhaust Monitoring 

IMO Scheme 

Scheme B Vessel Install Contact Olav Knudsen Aalborg Industries 

System Availability 1 MW to 50 MW Size, Land Based 

Install 

1 MW, in 2008 

Development Phase Prototype Size, Shipboard Install 21 MW, in 2009 

Failure Modes If an interruption occurs, the 

bypass valves open and the 

exhaust gas flow will bypass the 

EGC system. 

Failure Recovery The problem must be solved after 

which the system will return to 

normal operation automatically. The 

EGC can be remotely checked on 

trouble shooting by Aalborg 

Industries. 

Unit 

Size* 

(MW) 

Commercially 

Available 

(Yes/No) 

Land-based 

Trial 

(Year/Units) 

Shipboard 

Trial 

(Year/Units) 

Efficiency 

Results 

Available 

(Yes/No) 

How Many Hours of 

Operation? Notes 

1MW Yes 2008 DNA Yes 150 Landbased test (in 

cooperation w/MAN)

21MW Yes DNA 2009 Yes 1000

System in test since 

April 2010 (on DFDS 

Tor Ficaria)

* Unit size refers to diesel engine size served. Boiler units are not considered in this survey. 

System Efficiency Trial Results 

Land-Based or Shipboard Trial Landbased at Holeby (Fresh 

Water)

Test Date Oct 2008 – Jan 

2009

Engine Make/Model MAN 5L21/31 50Hz Rated Power (MW) 1MW

Fuel Grade (RMG35, RME25, DMB, DMA) 2, 4% S Trial Load (MW) 25-50-75-100%

Fuel Sulfur SO2 CO2 CO2 PM 2.5 PM HC NOx CO 

Back 

Press 

(%) (ppm) (%) (g/kWhr) (kPa) 

Scrubber OFF 431ppm 5.5% TBD 1 TBD TBD 1050 

PPM

TBD 0

Scrubber ON 4ppm for 

Closed 

Loop

5.3% TBD 0.3-0.8 TBD TBD 950 

PPM

TBD 1-3

Reduction (%) 99% 3-8% TBD 30-80% TBD TBD 5-10% TBD TBD

\ 
Exhaust Gas Cleaning Systems, Selection Guide A-3 The Glosten Associates, Inc 

Appendix A, Technology Survey, Rev. – File No. 10047.01, 12 January 2011 

2 of 5 pages, Aalborg Industries Exhaust Gas Cleaning B.V. 

Land-Based or Shipboard Trial Shipboard test results will be 

released Oct 2010

Test Date TBD

Engine Make/Model TBD Rated Power (MW) TBD

Fuel Grade (RMG35, RME25, DMB, DMA) TBD Trial Load (MW) TBD

Fuel Sulfur SO2 CO2 CO2 PM 2.5 PM HC NOx CO 

Back 

Press 

(%) (ppm) (%) (g/kWhr) (kPa) 

Scrubber OFF TBD TBD TBD TBD TBD TBD TBD TBD TBD

Scrubber ON TBD TBD TBD TBD TBD TBD TBD TBD TBD

Reduction (%) TBD TBD TBD TBD TBD TBD TBD TBD TBD

Waste Streams 

Wash Water Overboard Discharge Open Loop System 50 Tons/MW-hr, for Closed Loop 0.1 Tons/MW-hr 

Must discharge in port? No, in closed loop zero discharge 

Meets IMO Wash Water Standards? Yes 

Meets EPA Vessel General Permit? Yes 

Meets California Ocean Plan 

Standards? 

TBD 

Sludge Residue Quantity <0.5Kg/MW-hr 

Hazardous waste as per EPA? DNA 

Disposal method? Can be treated as normal sludge. 

Solid Waste Quantity DNA 

Hazardous waste as per EPA? DNA 

Disposal method? DNA 
Exhaust Gas Cleaning Systems, Selection Guide A-4 The Glosten Associates, Inc 

Appendix A, Technology Survey, Rev. – File No. 10047.01, 12 January 2011 

3 of 5 pages, Aalborg Industries Exhaust Gas Cleaning B.V. 

System Details 

Unit Size (MW of Engine Served) 4 MW 

Electrical Load (In Port/In ECA/At Sea) (kW) In Port 20kW, Open Sea 40kW 

Chemical Usage (In Port/In ECA/At Sea) NaOH (caustic soda), 50% concentration, 27.5Kg/MW-hr 

(3.5%HFO) 

Exhaust Handling: Pressure drop at full load (kPa) 0.5-1Kpa/50-100 mmwc 

Does unit serve as silencer/spark arrestor? Yes 

System failure block free flow of exhaust? No 

Multiple engine inlet capable? Yes 

Seawater Supply Quantity (m3/hr) 270m3

/h 

Fresh Water Consumption (m3/hr) T=20C, 370 l/h 

Steam Supply (kg/hr, kPa) DNA 

Air Supply (kg/hr, kPa) DNA 

Other necessary utilities? DNA 

Component #1 Name EGC 36 

Weight in kilograms (Dry/Wet) Dry 11T/Wet 13T 

Size in meters (Width/Depth/Height) Diameter = 2.0m/W=3.5m/H=5.6m 

Access required in meters (Front/Side/Top) TBD 

Unit Size (MW of Engine Served) 8 MW 

Electrical Load (In Port/In ECA/At Sea) (kW) In Port 40kW, Open Sea 80kW 

Chemical Usage (In Port/In ECA/At Sea) NaOH (caustic soda), 50% concentration, 27.5Kg/MW-hr 

(3.5%HFO) 

Exhaust Handling: Pressure drop at full load (kPa) 0.5-1Kpa/50-100 mmwc 

Does unit serve as silencer/spark arrestor? Yes 

System failure block free flow of exhaust? No 

Multiple engine inlet capable? Yes 

Seawater Supply Quantity (m3/hr) 540m3

/h 

Fresh Water Consumption (m3/hr) T=20C, 740 l/h 

Steam Supply (kg/hr, kPa) DNA 

Air Supply (kg/hr, kPa) DNA 

Other necessary utilities? DNA 

Component #1 Name EGC 73 

Weight in kilograms (Dry/Wet) Dry 15T/Wet 18T 

Size in meters (Width/Depth/Height) Diameter = 2.9m/W=4.9m/H=7.0m 

Access required in meters (Front/Side/Top) TBD 
Exhaust Gas Cleaning Systems, Selection Guide A-5 The Glosten Associates, Inc 

Appendix A, Technology Survey, Rev. – File No. 10047.01, 12 January 2011 

4 of 5 pages, Aalborg Industries Exhaust Gas Cleaning B.V. 

Unit Size (MW of Engine Served) 16 MW 

Electrical Load (In Port/In ECA/At Sea) (kW) In Port 80kW, Open Sea 160kW 

Chemical Usage (In Port/In ECA/At Sea) NaOH (caustic soda), 50% concentration, 27.5Kg/MW-hr 

(3.5%HFO) 

Exhaust Handling: Pressure drop at full load (kPa) 0.5-1 Kpa / 50-100 mmwc 

Does unit serve as silencer/spark arrestor? Yes 

System failure block free flow of exhaust? No 

Multiple engine inlet capable? Yes 

Seawater Supply Quantity (m3/hr) 1080 m3

/h 

Fresh Water Consumption (m3/hr) T=20C, 1480 l/h 

Steam Supply (kg/hr, kPa) DNA 

Air Supply (kg/hr, kPa) DNA 

Other necessary utilities? DNA 

Component #1 Name EGC 146 

Weight in kilograms (Dry/Wet) Dry 23T/Wet 29T 

Size in meters (Width/Depth/Height) Diameter = 4m/W=6.7m/H=9m 

Access required in meters (Front/Side/Top) TBD 

Unit Size (MW of Engine Served) 32 MW 

Electrical Load (In Port/In ECA/At Sea) (kW) In Port 160kW, Open Sea 320kW 

Chemical Usage (In Port/In ECA/At Sea) NaOH (caustic soda), 50% concentration, 27.5Kg/MW-hr 

(3.5%HFO) 

Exhaust Handling: Pressure drop at full load (kPa) 0.5-1 Kpa / 50-100 mmwc 

Does unit serve as silencer/spark arrestor? Yes 

System failure block free flow of exhaust? No 

Multiple engine inlet capable? Yes 

Seawater Supply Quantity (m3/hr) 2160 m3

/h 

Fresh Water Consumption (m3/hr) T=20C, 2960 l/h 

Steam Supply (kg/hr, kPa) DNA 

Air Supply (kg/hr, kPa) DNA 

Other necessary utilities? DNA 

Component #1 Name EGC 292 

Weight in kilograms (Dry/Wet) Dry 38T/Wet 52T 

Size in meters (Width/Depth/Height) Diameter = 5.9m/W=10.6m/H=11.6m 

Access required in meters (Front/Side/Top) TBD 
Exhaust Gas Cleaning Systems, Selection Guide A-6 The Glosten Associates, Inc 

Appendix A, Technology Survey, Rev. – File No. 10047.01, 12 January 2011 

5 of 5 pages, Aalborg Industries Exhaust Gas Cleaning B.V. 

System Description (Provided by Supplier)

Aalborg Industries has more than 30 years of experience of supplying scrubbers as an integrated part of Inert Gas Systems (IGS)

onboard ships. During 2008, our experiences from these systems in combination with our experiences from supplying exhaust gas 

boilers after large marine diesel engines were used to design a scrubber test rig to cool and clean the exhaust from a test engine at 

MAN Diesel test facility in Denmark. The knowledge and experience from these tests were successively used to design an entire 

exhaust gas cleaning system (EGS) onboard DFDS’ Ro-Ro vessel “Tor Ficaria.” Installed after the 21 MW MAN engine, it is by far

the world’s largest exhaust gas cleaning system installed onboard a ship. The design work has been carried out in close co-operation 

with the marine engineers from DFDS and MAN Diesel.

The EGC system is a combined wet scrubbing system being able to operate in sea water (open loop) and fresh water (closed loop). 

At open sea, the system operates with sea water and saves the use of NaOH and fresh water. In harbours and estuaries with strict 

discharge criteria, the system can operate on fresh water in a closed loop system. The combined EGC system offers therefore 

maximum flexibility combined with the lowest operational costs. In addition, our Exhaust Gas Scrubber is: 

• A cost-saving solution (able to operate on HFO instead of expensive low sulphur MDO/MGO) 

• In compliance with MARPOL Annex VI – MEPC 58 and 59 

• Provides a sulphur removal rate >98% (exceeding the IMO requirements) 

• Traps up to 80% of Particulate Matter (PM) 

 
Exhaust Gas Cleaning Systems, Selection Guide A-7 The Glosten Associates, Inc 

Appendix A, Technology Survey, Rev. – File No. 10047.01, 12 January 2011 

BELCO Technologies, 1 of 3 pages 

Plus 1 Attachment: BELCO Installation List 

Contact Garrett Billemeyer, (973) 515-8902, billemeyer@belcotech.com 

Website: http://belcotech.dupont.com 

Technology Type(s) EDV, Open Loop and Closed 

Loop 

No Dry Chemical 

Other Products Wet Electrostatic Precipitators, Dry 

Electrostatic Precipitators, Semi-dry 

Scrubbers, TSS and FSS, SCR 

Syssterms, LoTOx Systems, 

LABSORB Regenerative SO2

Scrubbing Systems. 

Exhaust Monitoring 

IMO Scheme 

TBD Vessel Install Contact TBD 

System Availability 2 MW to 200 MW Size, Land Based 

Install 

TBD 

Development Phase Commercial Size, Shipboard Install TBD 

Failure Modes The Scrubber is designed to run 

dry and continuously for plus 

five years. Interrupted 

operations are not an issue. 

Failure Recovery NA 

Unit 

Size* 

(MW) 

Commercially 

Available 

(Yes/No) 

Land-based 

Trial 

(Year/Units) 

Shipboard 

Trial 

(Year/Units) 

Efficiency 

Results 

Available 

(Yes/No) 

How Many Hours of 

Operation? Notes 

List of land-based industrial applications available upon request.

* Unit size refers to diesel engine size served. Boiler units are not considered in this survey. 

System Efficiency Trial Results 

Land-Based or Shipboard Trial Shipboard Test Date TBD

Engine Make/Model 11,349 kW Engine Rated Power (MW) TBD

Fuel Grade (RMG35, RME25, DMB, DMA) 3% Sulfur Diesel Trial Load (MW) 514 RPM

Fuel Sulfur SO2 CO2 CO2 PM 2.5 PM HC NOx CO 

Back 

Press 

(%) (ppm) (%) (g/kWhr) (kPa) 

Scrubber OFF TBD TBD TBD TBD TBD TBD TBD TBD 0.6

Scrubber ON TBD TBD TBD TBD TBD TBD TBD TBD 0

Reduction (%) > 97% TBD TBD TBD TBD TBD TBD TBD TBD

\ 
Exhaust Gas Cleaning Systems, Selection Guide A-8 The Glosten Associates, Inc 

Appendix A, Technology Survey, Rev. – File No. 10047.01, 12 January 2011 

2 of 3 pages, Belco Technologies 

Waste Streams 

Wash Water Overboard Discharge Dependant on Inlet SOx/Fuel 

Must discharge in port? No overboard discharge 

Meets IMO Wash Water Standards? Yes 

Meets EPA Vessel General Permit? Yes 

Meets California Ocean Plan 

Standards? 

Yes 

Sludge Residue Quantity Dependant on engine operation and fuel usage 

Hazardous waste as per EPA? Dependant on fuel source – no solid waste generated 

Disposal method? Occasionally offloaded to waste hauler 

Solid Waste Quantity 0 

Hazardous waste as per EPA? We comply with all IMO regulations on waste streams 

Disposal method? None generated 

System Details 

All system details are based on specific design conditions. 

Unit Size (MW of Engine Served) TBD

Electrical Load (In Port/In ECA/At Sea) (kW) TBD 

Chemical Usage (In Port/In ECA/At Sea) TBD 

Exhaust Handling: Pressure drop at full load (kPa) TBD 

Does unit serve as silencer/spark arrestor? TBD 

System failure block free flow of exhaust? TBD 

Multiple engine inlet capable? TBD 

Seawater Supply Quantity (m3/hr) TBD 

Fresh Water Consumption (m3/hr) TBD 

Steam Supply (kg/hr, kPa) TBD 

Air Supply (kg/hr, kPa) TBD 

Other necessary utilities? TBD 

Component #1 Name TBD 

Weight in kilograms (Dry/Wet) TBD 

Size in meters (Width/Depth/Height) TBD 

Access required in meters (Front/Side/Top) TBD 
Exhaust Gas Cleaning Systems, Selection Guide A-9 The Glosten Associates, Inc 

Appendix A, Technology Survey, Rev. – File No. 10047.01, 12 January 2011 

3 of 3 pages, Belco Technologies 

System Description (Provided by Supplier)

The Benefits of BELCO® Marine Scrubbing Systems include: 

• Reliable and cost effective design — designed specifically for your vessels in conjunction with your engineering staff 

• Open tower design. Able to operate uninterrupted for many years concurrent with required dry dockings. No concern with plugging 

or maintenance shutdowns while at sea 

• No hot by-pass required 

• High efficiency of pollutant removal 

• Helps meet all IMO, SECA, EPA regulations, even when using high sulfur fuels • Designed to withstand upset conditions and 

temperature excursions 

• Designed to operate without shutdowns for periods in excess of 5 years 

• Able to use various reagents and regenerative buffers 

• Low pressure drop design 

• High reliability and durability 

• High efficiency 

Aftermarket Services and Spare Parts include: 

• Proprietary components 

• Replacement parts 

• Start-up support 

• Troubleshooting 

• Construction advisors 
Exhaust Gas Cleaning Systems, Selection Guide A-10 The Glosten Associates, Inc 

Appendix A, Technology Survey, Rev. – File No. 10047.01, 12 January 2011 

Couple Systems GmbH, 1 of 3 pages 

Contact Ralf Jürgens, +49 40 526000921, rj@couple-systems.com

Website: www.couple-systems.com 

Technology Type(s) DryEGCS Other Products DryEGCS can easily be combined 

with SCR technology offered by 

Couple Systems. It does not require 

any additional reheating. Also, PM 

app. 80 %, HC app. 60 % 

Exhaust Monitoring 

IMO Scheme 

B Vessel Install Contact Shipowner Braren 

www.reedereibraren.de 

System Availability 1MW up to 60MW Size, Land Based 

Install 3MW up to 100MW 

Development Phase Commercial Size, Shipboard Install 3.6MW 

Failure Modes Close exhaust gas dampers Failure Recovery Close exhaust gas dampers 

Unit 

Size* 

(MW) 

Commercially 

Available 

(Yes/No) 

Land-based 

Trial 

(Year/Units) 

Shipboard 

Trial 

(Year/Units) 

Efficiency 

Results 

Available 

(Yes/No) 

How Many Hours of 

Operation? Notes 

3.6 Yes DNA 2009/1 99% 3500 TBD

* Unit size refers to diesel engine size served. Boiler units are not considered in this survey. 

System Efficiency Trial Results 

Land-Based or Shipboard Trial Shipboard Test Date 2009/12/1

Engine Make/Model MaK8M32 Rated Power (MW) 3.6

Fuel Grade (RMG35, RME25, DMB, DMA) HFO 0.9%S Trial Load (MW) 1.2

Fuel Sulfur SO2 CO2 CO2 PM 2.5 PM HC NOx CO 

Back 

Press 

(%) (ppm) (%) (g/kWhr) (kPa) 

Scrubber OFF 258 6.44 TBD TBD TBD 113 1065 98 DNA

Scrubber ON 1 6.31 TBD TBD TBD 45 1054 153 0.8 across 

Scrubber

Reduction (%) 99% DNA TBD TBD TBD 60 DNA DNA TBD

\ 
Exhaust Gas Cleaning Systems, Selection Guide A-11 The Glosten Associates, Inc 

Appendix A, Technology Survey, Rev. – File No. 10047.01, 12 January 2011 

2 of 3 pages, Couple Systems GmbH 

Waste Streams 

Wash Water Overboard Discharge DNA 

Must discharge in port? DNA 

Meets IMO Wash Water Standards? DNA 

Meets EPA Vessel General Permit? DNA 

Meets California Ocean Plan 

Standards? 

DNA 

Sludge Residue Quantity DNA 

Hazardous waste as per EPA? DNA 

Disposal method? DNA 

Solid Waste Quantity DNA 

Hazardous waste as per EPA? DNA 

Disposal method? DNA 

System Details 

Unit Size (MW of Engine Served) 4MW 

Electrical Load (In Port/In ECA/At Sea) (kW) 12/12/12 

Chemical Usage (In Port/In ECA/At Sea) Calcium Hydroxide, 99%, .05 Tons/MW-hr, 

50 Kg/h, 50 Kg/h, 0 

Exhaust Handling: Pressure drop at full load (kPa) 1 

Does unit serve as silencer/spark arrestor? Yes 

System failure block free flow of exhaust? No 

Multiple engine inlet capable? Yes 

Seawater Supply Quantity (m3/hr) DNA 

Fresh Water Consumption (m3/hr) DNA 

Steam Supply (kg/hr, kPa) DNA 

Air Supply (kg/hr, kPa) DNA 

Other necessary utilities? DNA 

Component #1 Name DryEGCS Absorber 

Weight in kilograms (Dry/Wet) 57,000 

Size in meters (Width/Depth/Height) 3.85/5.60/7.80 

Access required in meters (Front/Side/Top) 0.6/0.6/0.5 

Component #2 Name Supply and Discharge System 

Weight in kilograms (Dry/Wet) 24,000 

Size in meters (Width/Depth/Height) 2.40/2.40/6.0 

Access required in meters (Front/Side/Top) 0.6/0.6/0.5 
Exhaust Gas Cleaning Systems, Selection Guide A-12 The Glosten Associates, Inc 

Appendix A, Technology Survey, Rev. – File No. 10047.01, 12 January 2011 

3 of 3 pages, Couple Systems GmbH 

System Description (Provided by Supplier)

Couple Systems GmbH, Bardowick, Germany, brought the worldwide first and only dry system for the desulphurisation of exhaust 

gases of commercial vessels successfully into service on MS Timbus. Motorenwerke Bremerhaven (MWB AG) was able to install the 

system in less than a week’s time with high precision and impeccable workmanship on the cellulose freighter MS Timbus (MaK 

8M32, 3.6 MW) of the shipowning company Reederei Braren, Kollmar, Germany. Germanischer Lloyd (GL) has now taken 

outstanding test readings on the system. This clearly proves the feasibility of the DryEGCS ® on board ships and the full compliance 

of the system with the requirements with of Marpol Annex VI. Couple Systems GmbH provides a technical solution, proven and 

readily available to shipping. A continuation of the HFO-era is ecologically possible. A Return-on-Invest when purchasing a 

DryEGCS® in the light of today’s fuel prices, for ships that mainly navigate in the ECA North- and Baltic-Sea, is possible in one year. 

The 240° to 350°C hot exhaust gas, which contains SO2 and SO3, is fed through a packed-bed absorber filled with lime (calcium 

hydroxide Ca(OH)2) in the form of granulate pellets. The reaction product is CaSO4 i.e. gypsum. The spherical form of the granulate 

is retained. The ship’s ballast chambers, cargo space, and other open, storage areas on the ship provide storage for recyclables. 

DryEGCS® is dimensioned conservatively so that the collection efficiency is reliably achieved. The loading limit for the calcium 

hydroxide granulate is about 60%. Thus the absorbent material retains a considerable residual activity for desulphurisation. 

Alternatively, the residues can be used as mine filling. In this case, costs of approximately US-$ 100 per metric ton can be expected. 

 
Exhaust Gas Cleaning Systems, Selection Guide A-13 The Glosten Associates, Inc 

Appendix A, Technology Survey, Rev. – File No. 10047.01, 12 January 2011 

Ecospec, 1 of 4 pages 

Contact Tany Tay, +65 6602 9600, tany@ecospec.com

Website: www.ecospec.com 

Technology Type(s) CSNOx, an Ultra-Low 

Frequency Electrolysis System 

Other Products TBD 

Exhaust Monitoring 

IMO Scheme 

TBD Vessel Install Contact TBD 

System Availability TBD Size, Land Based 

Install 

TBD 

Development Phase TBD Size, Shipboard Install 11MW 

Failure Modes TBD Failure Recovery TBD 

Unit 

Size* 

(MW) 

Commercially 

Available 

(Yes/No) 

Land-based 

Trial 

(Year/Units) 

Shipboard 

Trial 

(Year/Units) 

Efficiency 

Results 

Available 

(Yes/No) 

How Many Hours of 

Operation? Notes 

TBD TBD 2009/1 DNA Yes TBD

5MW TBD DNA 2010 Yes TBD

* Unit size refers to diesel engine size served. Boiler units are not considered in this survey. 

System Efficiency Trial Results 

Land-Based or Shipboard Trial Shore-Based Test Rig Test Date 2009

Engine Make/Model TBD Rated Power (MW) TBD

Fuel Grade (RMG35, RME25, DMB, DMA) TBD Trial Load (MW) TBD

Fuel Sulfur SO2 CO2 CO2 PM 2.5 PM HC NOx CO 

Back 

Press 

(%) (ppm) (%) (g/kWhr) (kPa) 

Scrubber OFF TBD TBD TBD TBD TBD TBD TBD TBD TBD

Scrubber ON TBD TBD TBD TBD TBD TBD TBD TBD TBD

Reduction (%) 99% 30-55% TBD TBD TBD TBD 50-80% TBD TBD

\ 
Exhaust Gas Cleaning Systems, Selection Guide A-14 The Glosten Associates, Inc 

Appendix A, Technology Survey, Rev. – File No. 10047.01, 12 January 2011 

2 of 4 pages, Ecospec 

Land-Based or Shipboard Trial Shipboard, Aframax Tanker Test Date 2010

Engine Make/Model Main Engine, 100,000-Tonne Oil 

Tanker

Rated Power (MW) 11MW

Fuel Grade (RMG35, RME25, DMB, DMA) 380 cSt, 3.64% Sulfur Trial Load (MW) 5MW

Fuel Sulfur SO2 CO2 CO2 PM 2.5 PM HC NOx CO 

Back 

Press 

(%) (ppm) (%) (g/kWhr) (kPa) 

Scrubber OFF TBD TBD TBD TBD TBD TBD TBD TBD TBD

Scrubber ON TBD TBD TBD TBD TBD TBD TBD TBD TBD

Reduction (%) 98.6-

98.9%

76.5-

77.1%

TBD TBD TBD TBD 64.5-

66.2%

TBD TBD

Waste Streams 

Wash Water Overboard Discharge Yes 

Must discharge in port? TBD 

Meets IMO Wash Water Standards? Yes 

Meets EPA Vessel General Permit? Yes 

Meets California Ocean Plan 

Standards? 

Yes 

Sludge Residue Quantity pH 6.7, PAH <1 ppb, Nitrates <0.066mg/l (ppm), Turbidity Δ8.7 NTU 

Hazardous waste as per EPA? TBD 

Disposal method? TBD 

Solid Waste Quantity TBD 

Hazardous waste as per EPA? TBD 

Disposal method? TBD 
Exhaust Gas Cleaning Systems, Selection Guide A-15 The Glosten Associates, Inc 

Appendix A, Technology Survey, Rev. – File No. 10047.01, 12 January 2011 

3 of 4 pages, Ecospec 

System Details 

Unit Size (MW of Engine Served) 5MW 

Electrical Load (In Port/In ECA/At Sea) (kW) TBD 

Chemical Usage (In Port/In ECA/At Sea) None 

Exhaust Handling: Pressure drop at full load (kPa) TBD 

Does unit serve as silencer/spark arrestor? TBD 

System failure block free flow of exhaust? TBD 

Multiple engine inlet capable? TBD 

Seawater Supply Quantity (m3/hr) TBD 

Fresh Water Consumption (m3/hr) TBD 

Steam Supply (kg/hr, kPa) TBD 

Air Supply (kg/hr, kPa) TBD 

Other necessary utilities? TBD 

Component #1 Name TBD 

Weight in kilograms (Dry/Wet) TBD 

Size in meters (Width/Depth/Height) TBD 

Access required in meters (Front/Side/Top) TBD 
Exhaust Gas Cleaning Systems, Selection Guide A-16 The Glosten Associates, Inc 

Appendix A, Technology Survey, Rev. – File No. 10047.01, 12 January 2011 

4 of 4 pages, Ecospec 

System Description (Provided by Supplier)

ABS, one of the world’s leading classification societies, has issued a statement on 8 February 2010 verifying the results of sulphur 

dioxide (SO2), carbon dioxide (CO2), nitrogen oxide (NOx) removal from the emissions of a trading 100,000-tonne Aframax tanker 

installed with the CSNOx gas abatement system. In the first load point verifications, part of the ongoing IMO Type Approval 

certification process, conducted during the last week of January 2010 onboard this 100,000-tonne oil tanker, at 50% gas load 

(equivalent to approximately 5 MW engine output), ABS issued a Statement of Fact on the performance of CSNOx system with the 

following results: 

Fuel: Type Temperature Sulfur Content 

380 cSt 50°C 3.64% 

Removal SO2 CO2 NOx: efficiencies: 98.6% - 98.9% 76.5% - 77.1% 64.5% - 66.2% 

Exhaust gas: Inlet Outlet: 212.3°C 33.5°C 

Wash water pH PAH Nitrates Temperature Turbidity Quality: 6.7 <1 ppb <0.066mg/l (ppm) 32°C Δ8.7 NTU 

This 100,000-tonne Singapore-registered oil tanker, which is owned and managed by leading shipping company Tanker Pacific, set 

sail from Singapore, travelling to the Middle East via Sri Lanka. Significantly, the removal efficiencies of the CSNOx system allows 

vessels installed with CSNOx to continue using normal heavy fuel and yet meet the 0.1% sulfur content as required by the EU 

Directive effective from 1 January 2010. The removal efficiency for NOx is the absolute reduction percentage. After translating this 

removal efficiency into the NOx emission requirement as per the Tier 1, 2 or 3 requirements, the CSNOx system is able to remove

NOx to such levels that vessels installed with it are able to meet even the strictest Tier 3 requirement. CSNOx truly is a cost-effective 

and efficient solution for solving the emission issues faced by the ship owners. In addition, the results also affirm CSNOx scalability 

and suitability for a normal ship’s operations. 

 
Exhaust Gas Cleaning Systems, Selection Guide A-17 The Glosten Associates, Inc 

Appendix A, Technology Survey, Rev. – File No. 10047.01, 12 January 2011 

Hamworthy Krystallon Ltd /Hamworthy Moss, 1 of 4 pages 

Contact Heidi Marie Johannessen, +47 6927 9900, hkjohannessen@hamworthy.com

Website: http://www.hamworthy.com/en/Products-Systems/HamworthyMarine/Emissions-Reduction/Exhaust-Gas-Cleaning/

Technology Type(s) Open Loop (Closed Loop under 

Development) 

No Dry Chemical 

Hybrid Wet Solution Available 

Other Products The Hamworthy Krystallon SOx 

scrubber also acts as a Particulates 

scrubber. Stand alone PM scrubbers 

also available 

Exhaust Monitoring 

IMO Scheme 

Scheme B Vessel Install Contact TBD 

System Availability 0.5 MW to 60 MW Size, Land Based 

Install 

0.4MW, 1MW, 2.2MW 

Development Phase Commercial Size, Shipboard Install 1MW, 6MW, 8.5MW, 

Failure Modes Power loss, multiple supply 

pump failure, leakage (return 

pipes or scrubber), clogging of 

the wet filter. 

Failure Recovery If the issue is with the supply or 

return pump, then the system can be 

restarted as soon as the pump is 

repaired. 

Unit 

Size* 

(MW) 

Commercially 

Available 

(Yes/No) 

Land-based 

Trial 

(Year/Units) 

Shipboard 

Trial 

(Year/Units) 

Efficiency 

Results 

Available 

(Yes/No) 

How Many Hours of 

Operation? Notes 

0.5 Yes 2005/1 Yes 500 Test Unit

1 Yes 2008/1 2005/1 Yes 30,000

2 Yes 2008/1 No 0 Power Plant installation 

not yet finished

6 No 1993/1 Yes 8000 Initial Hamworthy 

design

8 Yes 2007/1 Yes 4000

* Unit size refers to diesel engine size served. Boiler units are not considered in this survey. 

System Efficiency Trial Results 

Land-Based or Shipboard Trial Land Based Test Date 2009

Engine Make/Model DM “MTE40” Rated Power (MW) 0.9MW

Fuel Grade (RMG35, RME25, DMB, DMA) TBD Trial Load (MW) Various

Fuel Sulfur SO2 CO2 CO2 PM 2.5 PM HC NOx CO 

Back 

Press 

(%) (ppm) (%) (g/kWhr) (kPa) 

Scrubber OFF 340 ppm DNA DNA TBD TBD TBD TBD TBD TBD

Scrubber ON 4 ppm TBD TBD TBD TBD TBD TBD TBD TBD

Reduction (%) 99% TBD TBD DNA 60% DNA DNA DNA 25

\ 
Exhaust Gas Cleaning Systems, Selection Guide A-18 The Glosten Associates, Inc 

Appendix A, Technology Survey, Rev. – File No. 10047.01, 12 January 2011 

2 of 4 pages, Hamworthy Krystallon Ltd /Hamworthy Moss 

Land-Based or Shipboard Trial Shipboard Test Date 2009

Engine Make/Model Sulzer 6ATL25H Rated Power (MW) 0.8MW

Fuel Grade (RMG35, RME25, DMB, DMA) IF380 Trial Load (MW) TBD

Fuel Sulfur SO2 CO2 CO2 PM 2.5 PM HC NOx CO 

Back 

Press 

(%) (ppm) (%) (g/kWhr) (kPa) 

Scrubber OFF 330 ppm DNA DNA TBD TBD TBD TBD TBD TBD

Scrubber ON 12 ppm TBD TBD TBD TBD TBD TBD TBD TBD

Reduction (%) 96.5% TBD TBD DNA 60% DNA DNA DNA 25

Land-Based or Shipboard Trial Shipboard Test Date 2010

Engine Make/Model Sulzer 12VZA40S Rated Power (MW) 0.8MW

Fuel Grade (RMG35, RME25, DMB, DMA) IF380 Trial Load (MW) 7.4

Fuel Sulfur SO2 CO2 CO2 PM 2.5 PM HC NOx CO 

Back 

Press 

(%) (ppm) (%) (g/kWhr) (kPa) 

Scrubber OFF 340ppm DNA DNA TBD TBD TBD TBD TBD TBD

Scrubber ON 4ppm TBD TBD TBD TBD TBD TBD TBD TBD

Reduction (%) 99% TBD TBD DNA 60% DNA DNA DNA 25

Waste Streams 

Wash Water Overboard Discharge 45 Tons/MW-hr 

Must discharge in port? Yes 

Meets IMO Wash Water Standards? Yes 

Meets EPA Vessel General Permit? Yes 

Meets California Ocean Plan 

Standards? 

Meets MARPOL Annex VI 

Sludge Residue Quantity <0.1kg/MW.hr 

Hazardous waste as per EPA? No 

Disposal method? 1) With ships waste oil, and 2) In portable containers 

Solid Waste Quantity 0 

Hazardous waste as per EPA? DNA 

Disposal method? DNA 
Exhaust Gas Cleaning Systems, Selection Guide A-19 The Glosten Associates, Inc 

Appendix A, Technology Survey, Rev. – File No. 10047.01, 12 January 2011 

3 of 4 pages, Hamworthy Krystallon Ltd /Hamworthy Moss 

System Details 

Unit Size (MW of Engine Served) 8 MW 

Electrical Load (In Port/In ECA/At Sea) (kW) 75/120/120 

Chemical Usage (In Port/In ECA/At Sea) 0 

Exhaust Handling: Pressure drop at full load (kPa) 20 kPa 

Does unit serve as silencer/spark arrestor? Yes 

System failure block free flow of exhaust? Yes 

Multiple engine inlet capable? Yes 

Seawater Supply Quantity (m3/hr) 360 m3

/hr @ 600kPa 

Fresh Water Consumption (m3/hr) 0 

Steam Supply (kg/hr, kPa) 450 kg/hr(deplume)@100kPa 

Air Supply (kg/hr, kPa) For instruments only 

Other necessary utilities? DNA 

Component #1 Name 2MW 

Weight in kilograms (Dry/Wet) 3500/4750 kg 

Size in meters (Width/Depth/Height) 1.4/1.4/5 

Access required in meters (Front/Side/Top) 600 mm 

Exhaust Handling: Pressure drop at full load (kPa) 8 MW 

Does unit serve as silencer/spark arrestor? Yes 

System failure block free flow of exhaust? No 

Multiple engine inlet capable? Yes 
Exhaust Gas Cleaning Systems, Selection Guide A-20 The Glosten Associates, Inc 

Appendix A, Technology Survey, Rev. – File No. 10047.01, 12 January 2011 

4 of 4 pages, Hamworthy Krystallon Ltd /Hamworthy Moss 

System Description (Provided by Supplier)

The Hamworthy Krystallon sea water scrubbing technology will remove more than 98% of sulphur along with the majority of 

particulate matter from a 3.5% sulphur residual fuel. The technology is suitable for both new build and retrofit applications, and will 

deliver ease of operation and low maintenance costs. The technology is available for a wide range of vessel and engine 

configurations. Hamworthy Krystallon can offer; 

1. Pre-installation design support and shipyard supervision 

2. A full post-installation commissioning service 

3. After sales and service support through Hamworthy’s extensive service network worldwide 

4. Access to innovative project financing and fuels supply risk management 

The Sea Water Scrubber unit is manufactured from high nickel chrome alloy steels ensuring long lifetime and reliable operation. It 

can fit into the funnel space being both lightweight and self supporting. Whilst the Scrubber is designed to run cool, operating on a 

constant supply of sea water, under emergency conditions it can be operated at temperatures of up to 450°C. It also provides for 

silencing of the engine exhaust noise, and may therefore replace a typical exhaust gas silencer. The main sea water intake pipe work 

is manufactured from glass reinforced epoxy. This provides high corrosion resistance, low flow losses, light weight, and ease of 

installation. Water is transferred around the system via Hamworthy’s own trusted centrifugal pumps. 

The wash water treatment system will handle the full Scrubber Unit water flow. It is designed to remove both solid particulate matter 

and liquid hydrocarbon waste products. All exposed materials and wash water transfer pipe work are also manufactured from 

corrosion proof glass reinforced epoxy. The high efficiency design complies with the requirements of MARPOL Annex VI 

Regulation 14 Sea Water Scrubbing Wash Water Criteria. 

Hamworthy has over 25 years experience of sea water scrubbing through its Inert Gas operation in Moss. Our knowledge and detailed 

engineering capability allied with Hamworthy Krystallon technology is unique in the marine market place. 
Exhaust Gas Cleaning Systems, Selection Guide A-21 The Glosten Associates, Inc 

Appendix A, Technology Survey, Rev. – File No. 10047.01, 12 January 2011 

Marine Exhaust Solutions, 1 of 3 pages 

Contact Robert Clarke, (506) 214-0535, rclarke@marineexhaustsolutions.com 

Website: www.marineexhaustsolutions.com 

Technology Type(s) Seawater Scrubbing System Other Products J series for PM reduction on diesel 

fuel engines, 

NOx reduction unit for MAN Diesel. 

Exhaust Monitoring 

IMO Scheme 

TBD Vessel Install Contact TBD 

System Availability TBD Size, Land Based 

Install 

DNA 

Development Phase TBD Size, Shipboard Install 1.2 to 5.6MW 

Failure Modes Water carryover prevented full 

time running during tests. 

Failure Recovery Run in dry mode until fixed. 

Unit 

Size* 

(MW) 

Commercially 

Available 

(Yes/No) 

Land-based 

Trial 

(Year/Units) 

Shipboard 

Trial 

(Year/Units) 

Efficiency 

Results 

Available 

(Yes/No) 

How Many Hours of 

Operation? Notes 

22.7 No DNA 2003/8 Yes 11,680 

15.0 TBD DNA 2001 Yes TBD Trials spanned 6 mos. 

* Unit size refers to diesel engine size served. Boiler units are not considered in this survey. 

System Efficiency Trial Results 

Land-Based or Shipboard Trial Shipboard, RORO ferry Test Date March 2003

Engine Make/Model Two engine packages, type TBD Rated Power (MW) Four 5.6MW 

mains and four 

1.2MW 

auxiliary 

engines

Fuel Grade (RMG35, RME25, DMB, DMA) Heavy Fuel 2.4% Sulfur Trial Load (MW) 22.7

Fuel Sulfur SO2 CO2 CO2 PM 2.5 PM HC NOx CO 

Back 

Press 

(%) (ppm) (%) (g/kWhr) (kPa) 

Scrubber OFF 235T/yr TBD TBD TBD TBD TBD TBD TBD TBD

Scrubber ON 59T/yr TBD TBD TBD TBD TBD TBD TBD In Limits

Reduction (%) 74-80% TBD TBD TBD TBD TBD TBD TBD TBD

Land-Based or Shipboard Trial Shipboard, Ferry Test Date 2001

Engine Make/Model TBD Rated Power (MW) 1.5MW

Fuel Grade (RMG35, RME25, DMB, DMA) Heavy Fuel 2.4% Sulfur Trial Load (MW) TBD

Fuel Sulfur SO2 CO2 CO2 PM 2.5 PM HC NOx CO 

Back 

Press 

(%) (ppm) (%) (g/kWhr) (kPa) 

Scrubber OFF TBD TBD TBD TBD TBD TBD TBD TBD TBD

Scrubber ON TBD TBD TBD TBD TBD TBD TBD TBD TBD

Reduction (%) 90% TBD TBD TBD TBD TBD TBD TBD TBD
Exhaust Gas Cleaning Systems, Selection Guide A-22 The Glosten Associates, Inc 

Appendix A, Technology Survey, Rev. – File No. 10047.01, 12 January 2011 

2 of 3 pages, Marine Exhaust Solutions 

Waste Streams 

Wash Water Overboard Discharge Yes 

Must discharge in port? No 

Meets IMO Wash Water Standards? Yes 

Meets EPA Vessel General Permit? Yes 

Meets California Ocean Plan 

Standards? 

TBD 

Sludge Residue Quantity 0.6T/week 

Hazardous waste as per EPA? TBD 

Disposal method? Onshore 

Solid Waste Quantity 0.6T/week 

Hazardous waste as per EPA? TBD 

Disposal method? Onshore 

System Details 

Unit Size (MW of Engine Served) TBD 

Electrical Load (In Port/In ECA/At Sea) (kW) TBD 

Chemical Usage (In Port/In ECA/At Sea) TBD 

Exhaust Handling: Pressure drop at full load (kPa) TBD 

Does unit serve as silencer/spark arrestor? TBD 

System failure block free flow of exhaust? TBD 

Multiple engine inlet capable? TBD 

Seawater Supply Quantity (m3/hr) TBD 

Fresh Water Consumption (m3/hr) TBD 

Steam Supply (kg/hr, kPa) TBD 

Air Supply (kg/hr, kPa) TBD 

Other necessary utilities? TBD 

Component #1 Name TBD 

Weight in kilograms (Dry/Wet) TBD 

Size in meters (Width/Depth/Height) TBD 

Access required in meters (Front/Side/Top) TBD 
Exhaust Gas Cleaning Systems, Selection Guide A-23 The Glosten Associates, Inc 

Appendix A, Technology Survey, Rev. – File No. 10047.01, 12 January 2011 

3 of 3 pages, Marine Exhaust Solutions 

System Description (Provided by Supplier)

Throughout the 16-month trials onboard the RORO passenger ferry, the auxiliary engines were operational for approximately 11680

hours and consumed 6272 tonnes of fuel. During this time, based on a reduction rate of 75%, the EcoSilencer® removed 235.5 of the 

314 Tonnes of SO2. In particular: 

• A sustainable SO2 removal level of 74% – 80% was obtained with a maximum/minimum range of 94% to 68%. 

• The target removal of 90% was only achievable by overcharging the existing water circulation system. Proposed 

modifications to the circulating water system are expected to result in higher SO2 removal without the necessity of 

overcharging. 

• Tests showed the overboard water discharge complies with USA EPA test criteria. 

• Engine performance was not compromised. System backpressures remained within the engines’ accepted limits. 

• No indication of an increase in engine fuel consumption was noted. 

• Soot sludge removal amounted to approximately 0.6 T/week and was easily handled as part of the ships regular onshore 

waste disposal. 

• Minimal system maintenance was required. Routine maintenance consisted of, periodical boroscope type inspections, water 

circulation pump maintenance and periodical cleaning of the level measuring probes. 

• Further trials are needed to confirm the design modifications that will achieve the targeted 90% SO2 removal rates for the 

main engines. The challenge of scaling the system design from a single unit at 1500 kW to eight units at 22700 kW as well 

as manufacturing, shipping and installation within the four months available proved to be greater than anticipated. A lack of 

time to properly model the design for the main engine units resulted in installing a system that required additional 

modifications to become operational. 

The final result demonstrates that the EcoSilencer® is a reliable, low maintenance sea water scrubbing system that achieves reductions 

in SO2 emissions that far exceed those mandated by MARPOL Annex VI. 

 
Exhaust Gas Cleaning Systems, Selection Guide A-24 The Glosten Associates, Inc 

Appendix A, Technology Survey, Rev. – File No. 10047.01, 12 January 2011 

Wärtsilä Finland Oy, 1 of 4 pages 

Contact 

Technology Type(s) Closed Loop, High Sulfur SCR Other Products Wärsilä NOx Reducer 

Exhaust Monitoring 

IMO Scheme 

A and B Vessel Install Contact TBD 

System Availability TBD Size, Land Based 

Install 

TBD 

Development Phase Commercial Size, Shipboard Install 0.68MW 

Failure Modes TBD Failure Recovery TBD 

Unit 

Size* 

(MW) 

Commercially 

Available 

(Yes/No) 

Land-based 

Trial 

(Year/Units) 

Shipboard 

Trial 

(Year/Units) 

Efficiency 

Results 

Available 

(Yes/No) 

How Many Hours of 

Operation? Notes 

.68MW Yes TBD 2008/2 Yes TBD IMO Certification 

* Unit size refers to diesel engine size served. Boiler units are not considered in this survey. 

System Efficiency Trial Results 

Land-Based or Shipboard Trial Shipboard Test Date 2008-2010 

Engine Make/Model Wärtsilä 4L20 Rated Power (MW) 0.68MW

Fuel Grade (RMG35, RME25, DMB, DMA) HFO 1.5% and 3.4%S Trial Load (MW) 8, 40, 70, and 

100% Load

Fuel Sulfur SO2 CO2 CO2 PM 2.5 PM HC NOx CO 

Back 

Press 

(%) (ppm) (%) (g/kWhr) (kPa) 

Scrubber OFF TBD TBD TBD TBD TBD TBD TBD TBD TBD

Scrubber ON TBD TBD TBD TBD TBD TBD TBD TBD TBD

Reduction (%) >99% TBD TBD TBD TBD TBD TBD TBD TBD

\ 
Exhaust Gas Cleaning Systems, Selection Guide A-25 The Glosten Associates, Inc 

Appendix A, Technology Survey, Rev. – File No. 10047.01, 12 January 2011 

2 of 4 pages, Wärtsilä Finland Oy 

Land-Based or Shipboard Trial Test Date 

Engine Make/Model Rated Power (MW) MW

Fuel Grade (RMG35, RME25, DMB, DMA) Trial Load (MW) MW

Fuel Sulfur SO2 CO2 CO2 PM 2.5 PM HC NOx CO 

Back 

Press 

(%) (ppm) (%) (g/kWhr) (kPa) 

Scrubber OFF TBD TBD TBD TBD TBD TBD TBD TBD TBD

Scrubber ON TBD TBD TBD TBD TBD TBD TBD TBD TBD

Reduction (%) TBD TBD TBD TBD TBD TBD

Waste Streams 

Wash Water Overboard Discharge 0.1 

Must discharge in port? No 

Meets IMO Wash Water Standards? Yes 

Meets EPA Vessel General Permit? TBD 

Meets California Ocean Plan 

Standards? 

TBD 

Sludge Residue Quantity 0.0013 Tons/MW-hr 

Hazardous waste as per EPA? No 

Disposal method? Same as Engine Room sludge. 

Solid Waste Quantity 0 

Hazardous waste as per EPA? DNA 

Disposal method? DNA 
Exhaust Gas Cleaning Systems, Selection Guide A-26 The Glosten Associates, Inc 

Appendix A, Technology Survey, Rev. – File No. 10047.01, 12 January 2011 

3 of 4 pages, Wärtsilä Finland Oy 

System Details 

Unit Size (MW of Engine Served) 8MW (main stream scrubber) 

Electrical Load (In Port/In ECA/At Sea) (kW) 24 kW 

Chemical Usage (In Port/In ECA/At Sea) Case dependent, 50% concentration NaOH 

Exhaust Handling: Pressure drop at full load (kPa) 800 kPa 

Does unit serve as silencer/spark arrestor? Partly 

System failure block free flow of exhaust? No 

Multiple engine inlet capable? Yes 

Seawater Supply Quantity (m3/hr) TBD 

Fresh Water Consumption (m3/hr) 0.8 m3

/hr 

Steam Supply (kg/hr, kPa) DNA 

Air Supply (kg/hr, kPa) TBD 

Other necessary utilities? TBD 

Component #1 Name Scrubber Unit 

Weight in kilograms (Dry/Wet) 6000/8000 

Size in meters (Width/Depth/Height) 2.8/2.8/6 

Access required in meters (Front/Side/Top) TBD 
Exhaust Gas Cleaning Systems, Selection Guide A-27 The Glosten Associates, Inc 

Appendix A, Technology Survey, Rev. – File No. 10047.01, 12 January 2011 

4 of 4 pages, Wärtsilä Finland Oy 

System Description (Provided by Supplier)

Wärtsilä has developed a feasible scrubber solution, both for new installations and as a retrofit to existing ships. Combustion units can 

be diesel engines of any make, type, or application, 2-stroke or 4-stroke. In the case of Integrated Scrubber, also flue gases of oil-fired 

boilers can be cleaned. The SOx removal efficiency of Wärtsilä scrubber system is over 97%, making possible to operate with 3.5% 

sulphur fuel and still comply with 0.1% sulphur fuel limit. There are different scrubber configurations available. The scrubber system 

is equipped with an automation system for operation, monitoring, and safety control. Wärtsilä scrubber system has been approved by 

classification societies. 

The Wärtsilä fresh water scrubber is based on closed loop system. Within this process, sulphur oxides in the exhaust gas stream are 

captured and neutralized by scrubbing water. The scrubbing water is based on fresh water boosted with alkali, typically sodium

hydroxide (NaOH). The chemical process sulphur oxides resulting from the exhaust gas are neutralized to sulphates in the scrubbing 

water. The scrubber system is entirely built of highly corrosion resistant materials. Scrubbing water circulation flow rate is related to 

the actual dimensions of the scrubber module and design performance of the system. Scrubbing water is buffered in a process tank or 

wet sump for controlling the quality of the solution. This water is circulated with circulation pump from process tank or wet sump via 

the cooling heat exchanger to scrubber and back. A small bleed-off is extracted from the scrubbing water circulation to remove the 

accumulated impurities and led to treatment unit. Clean effluent from the treatment unit is monitored full-filling IMO quality

requirements and can be discharged overboard. If operation in zero discharge mode is requested, the effluent can be led to a holding 

tank for scheduled and periodical discharge. 
Exhaust Gas Cleaning Systems, Selection Guide The Glosten Associates, Inc 

Appendix B, Life Cycle Cost Tables, Rev. – File No. 10047.01, 12 January 2011 

Appendix B Life Cycle Cost Tables 

This Appendix provides the tables that were developed to support the life cycle cost analysis performed for the 

Ship Operations Cooperative Program (SOCP) marine exhaust gas cleaning system (EGCS) selection guide. 
Containership

Transpacific

Containership

Alaska to Puget

Sound

Tankship US

West Coast

Ship Speed (knots) 23 20 14.5

Port Name Shanghai Tacoma Anacortes

Distance from Last (n.miles) 5345 1453 1117

non‐ECA (n.miles) 4584 726.5 0

ECA (n.miles) 761 726.5 1117

Transit Time

non‐ECA (days) 8.30 1.51 0.00

ECA (days) 1.38 1.51 3.21

Port Time (days) 2.00 0.25 0.75

Port Name Los Angeles Anchorage Long Beach

Distance from Last (n.miles) 5643 1453 1117

non‐ECA (n.miles) 4882 726.5 0

ECA (n.miles) 761 726.5 1117

Transit Time

non‐ECA (days) 8.84 1.51 0.00

ECA (days) 1.38 1.51 3.21

Port Time (days) 1.00 0.42 0.75

Port Name Oakland

Distance from Last (n.miles) 374

non‐ECA (n.miles) 0

ECA (n.miles) 374

Transit Time

non‐ECA (days) 0.0

ECA (days) 0.7

Port Time (days) 1.0

Trip Total (days) 24.6 6.7 7.9

Transit Time

non‐ECA (days) 17.1 3.0 0.0

ECA (days) 3.4 3.0 6.4

Port Time (ECA) (days) 4.0 0.7 1.5

Notes:

1. Containership route and speed based on simplified Horizon Lines Eastern run.

2. Trailership route and speed based on TOTE Alaskan service run.

3. Tankship route based on product trade on West Coast.  Speeds are typical.

4. Ocean transits assume Great Circle route.

5. U.S. port to port uses NOAA estimated distances.

6. ECA entry from Ocean assumes a run at 45 degrees to account for maneuvering.

7. ECA from AK to Puget Sound is rough estimate of 50% based on geography.

Exhaust Gas Cleaning Systems

Operators Guide

Life Cycle Cost ‐ Ship Transits

Sheet 1 of 77

The Glosten Associates

File 10047.01, 12 January 2011
Containership

Transpacific

Containership

Alaska to Puget

Sound

Tankship US

West Coast

Installed Equipment

Propulsion (kW) 1 x 36,000 1 x 16,000 1 x 10,100

(gr/kW‐hr) 170 175 175

Auxiliary (kW) 3 x 1,000 4 x 1500 3 x 1,000

(gr/kW‐hr) 185 185 185

Annual Ops (days) 320 320 320

Transit (kW) 30,200 14,700 9,000

Non‐ECA (hours/yr) 5,357 3,459 0

Fuel (MT/yr) 27,502 8,899 0

ECA (hours/yr) 1,074 3,459 6,225

Fuel (MT/yr) 5,512 8,899 9,805

Ships Service (kW) 1200 800 350

Non‐ECA (hours/yr) 5,357 3,459 0

Fuel (MT/yr) 1,189 512 0

ECA (hours/yr) 2,323 4,221 7,680

Fuel (MT/yr) 516 625 497

Cargo Support (kW) 800 800 2000

ECA (hours/yr) 1,250 762 1,455

Fuel (MT/yr) 185 113 538

Fuel Total Fuel (MT/yr) 34,903 19,046 10,840

Non‐ECA Fuel (MT/yr) 28,691 9,410 0

ECA Fuel (MT/yr) 6,212 9,636 10,840

Notes:

1. Container Transpacific propulsion power based on 4000 TEU ship, MAN Containerships Trends 2008.

2. Container Alaska propulsion power based on 2000 TEU ship, MAN Containerships Trends 2008.

3. Tankship propulsion power based on 60,000 DWT, MAN Tankship Trends 2008.

4. Cargo and Ship Service loads are rough estimates.

5. Engine fuel consumptions based on 2 stroke diesels for propulsion, and 4 stroke for

  generators.  Using rough estimates from Wartsila.

Exhaust Gas Cleaning Systems

Operators Guide

Life Cycle Cost ‐ Fuel Consumption

Sheet 2 of 77

The Glosten Associates

File 10047.01, 12 January 2011
Open Loop Closed Loop Hybrid Dry

Scrubber Ratings

(by Engine Size) (USD) (USD) (USD) (USD)

36MW 3,100,000 3,850,000 3,600,000 6,050,000

16MW 2,900,000 3,600,000 3,120,000 3,200,000

12MW 2,000,000 2,500,000 2,220,000 1,900,000

10MW 1,800,000 2,150,000 1,920,000 1,600,000

3MW 1,300,000 1,850,000 1,560,000 1,250,000

1MW 1,000,000 1,750,000 1,260,000 930,000

Containership

Transpacific 5,260,000 6,430,000 5,904,000 7,970,000

Containership Alaska to

Puget Sound 5,060,000 6,180,000 5,424,000 5,120,000

Tankship US West Coast 3,960,000 4,730,000 4,224,000 3,520,000

Notes:

1. Costs are for vendor supplied equipment and support only.

2. Costs based on ROMs from vendors (+/‐ 20%) plus adjustments to level scope.

3. Vessel estimates based on propulsion plants.

4. Assume ‐ auxiliary engines combined into one large scrubber.

Exhaust Gas Cleaning Systems

Operators Guide

Life Cycle Cost ‐ Scrubber Costs

Sheet 3 of 77

The Glosten Associates

File 10047.01, 12 January 2011
Ship/Route Pair

Containership

Transpacific

Containership

Alaska to Puget

Sound

Tankship US

West Coast

Scrubber Type Open Loop Open Loop Open Loop

VARIABLES ‐ CONTROLLEDInvestment Terms

Life Cycle (# of Years) 10 10 10

Analysis Date (Today) (Year) 2011 2011 2011

Scrubber Installation Date (Year) 2014 2014 2014Discount Rate (%) 10.0% 10.0% 10.0%

Capital Expense for Scrubber

Equipment (Today) (USD/One Time) $5,260,000 $5,060,000 $3,960,000

Engineering/Design (% Equip Cost) 7.0% 7.0% 7.0%

Training/Documents (% Equip Cost) 2.0% 2.0% 2.0%Install/Commission (% Equip Cost) 50.0% 50.0% 50.0%

Operating Expense ‐ Annual

ECA Fuel Consumption (MT/Annual) 6,212 9,636 10,840

Chemical Consumption (% of Fuel Cost) 0.0% 0.0% 0.0%

Scrubber Parasitic Loads (% of Fuel Cost) 2.0% 2.0% 2.0%Distillate Calorie Correction (% of Fuel Cost) 4.0% 4.0% 4.0%HFO Process and Heating (% of Fuel Cost) 0.8% 0.8% 0.8%Operating Engineer (Today) (USD/Annual) $292,000 $292,000 $292,000

Operating Engineer (% of Position) 50.0% 50.0% 50.0%

M&R Equipment (% Equip Cost/Annual) 4.0% 4.0% 4.0%

Variables ‐ Uncertain

Fuel Differential (Today) (USD/MT) $255.50 $255.50 $255.50

Fuel/Chemical Escalation Rate (% ‐ Annual for Op Period) 8.0% 8.0% 8.0%

Personnel Inflation Rate (% ‐ Annual for Op Period) 3.0% 3.0% 3.0%Equipment Inflation Rate (% ‐ Annual for Op Period) 3.3% 3.3% 3.3%

Exhaust Gas Cleaning SystemsOperators Guide

Life Cycle Cost ‐ Baseline Summary

Sheet 4 of 77

Fil
Analysis Results ‐ Overview (Nearest $1,000)

Capital Cost (USD ‐ Year Zero Dollars) (9,219,000) (8,868,000) (6,941,000)

Expenses ‐ Year One (USD ‐ Year One Dollars) (551,000) (623,000) (601,000)

Fuel Savings ‐ Year One (USD ‐ Year One Dollars) 2,159,000 3,350,000 3,768,000

Net Present Value (USD ‐ 2011 Dollars) 4,851,000 14,562,000 20,110,000Internal Rate of Return (%) 20% 36% 53%

Exhaust Gas Cleaning SystemsOperators Guide

Life Cycle Cost ‐ Baseline Summary

Sheet 5 of 77

Fil
Inflation Baseline Year

Expenses Baseline 01234

Capital Cost ‐ Total (9,219,000)

Equipment (5,798,113)Acquisition (3,420,887)

Expenses ‐ Total (550,743) (575,326) (601,257) (628,626) 

Distillate Correction (86,377) (93,287) (100,750) (108,810) 

HFO Process & Heating (17,275) (18,657) (20,150) (21,762) Operating Engineer (164,324) (169,254) (174,332) (179,562) Chemical Consumption 0000

Scrubber Loads (43,188) (46,643) (50,375) (54,405) 

M&R Equip & Labor (239,578) (247,484) (255,651) (264,088) 

Savings ‐ Fuel Differential 2,159,415 2,332,168 2,518,742 2,720,241 NPV & IRR

Cash Flow (9,219,000) 1,608,673 1,756,843 1,917,485 2,091,616 

Discount Factor 1.0000 0.9091 0.8264 0.7513 0.6830 Present Value (9,219,000) 1,462,430 1,451,936 1,440,635 1,428,602 Net Present Value (at Year 0) 4,850,970

Internal Rate of Return 19.54%

Exhaust Gas Cleaning SystemsOperators Guide

Life Cycle Cost ‐ Baseline Detail

Sheet 6 of 77

Fil
Inflation Baseline

Expenses BaselineCapital Cost ‐ Total

EquipmentAcquisition

Expenses ‐ Total

Distillate Correction

HFO Process & Heating

Operating EngineerChemical Consumption

Scrubber LoadsM&R Equip & Labor

Savings ‐ Fuel DifferentialNPV & IRR

Cash FlowDiscount FactorPresent ValueNet Present Value (at Year 0)

Internal Rate of Return

Year

6 7 8 9 10

(688,058) (720,333) (754,467) (790,587) (828,826)

(126,916) (137,069) (148,034) (159,877) (172,667)

(25,383) (27,414) (29,607) (31,975) (34,533)

(190,497) (196,212) (202,098) (208,161) (214,406)

00000

(63,458) (68,534) (74,017) (79,939) (86,334)

(281,805) (291,105) (300,711) (310,634) (320,885)

3,172,889 3,426,720 3,700,858 3,996,927 4,316,681

2,484,831 2,706,387 2,946,391 3,206,340 3,487,855

0.5645 0.5132 0.4665 0.4241 0.3855

1,402,622 1,388,805 1,374,513 1,359,801 1,344,719

Exhaust Gas Cleaning SystemsOperators Guide

Life Cycle Cost ‐ Baseline Detail

Sheet 7 of 77

Fil
Inflation Baseline Year

Expenses Baseline 01234

Capital Cost ‐ Total (8,868,468)

Equipment (5,577,653)Acquisition (3,290,815)

Expenses ‐ Total (622,559) (653,316) (685,929) (720,528) 

Distillate Correction (133,980) (144,699) (156,275) (168,777) HFO Process & Heating (26,796) (28,940) (31,255) (33,755) Operating Engineer (164,324) (169,254) (174,332) (179,562) Chemical Consumption 0000

Scrubber Loads (66,990) (72,349) (78,137) (84,388) 

M&R Equip & Labor (230,469) (238,074) (245,931) (254,046) 

Savings ‐ Fuel Differential 3,349,508 3,617,469 3,906,867 4,219,416 NPV & IRR

Cash Flow (8,868,468) 2,726,949 2,964,153 3,220,937 3,498,888 

Discount Factor 1.0000 0.9091 0.8264 0.7513 0.6830 Present Value (8,868,468) 2,479,044 2,449,713 2,419,938 2,389,787 Net Present Value 14,562,028

Internal Rate of Return 36.17%

Exhaust Gas Cleaning SystemsOperators Guide

Life Cycle Cost ‐ Baseline Detail

Sheet 8 of 77

Fil
Inflation Baseline

Expenses BaselineCapital Cost ‐ Total

EquipmentAcquisition

Expenses ‐ Total

Distillate Correction

HFO Process & Heating

Operating EngineerChemical Consumption

Scrubber LoadsM&R Equip & Labor

Savings ‐ Fuel DifferentialNPV & IRR

Cash FlowDiscount FactorPresent ValueNet Present Value

Internal Rate of Return

Year

6 7 8 9 10

(796,251) (837,685) (881,727) (928,564) (978,397)

(196,861) (212,610) (229,619) (247,988) (267,827)

(39,372) (42,522) (45,924) (49,598) (53,565)

(190,497) (196,212) (202,098) (208,161) (214,406)

00000

(98,431) (106,305) (114,809) (123,994) (133,914)

(271,090) (280,036) (289,277) (298,823) (308,684)

4,921,527 5,315,249 5,740,469 6,199,706 6,695,683

4,125,276 4,477,564 4,858,742 5,271,142 5,717,286

0.5645 0.5132 0.4665 0.4241 0.3855

2,328,611 2,297,698 2,266,639 2,235,479 2,204,261

Exhaust Gas Cleaning SystemsOperators Guide

Life Cycle Cost ‐ Baseline Detail

Sheet 9 of 77

Fil
Inflation Baseline Year

Expenses Baseline 01234

Capital Cost ‐ Total (6,940,540)

Equipment (4,365,120)Acquisition (2,575,421)

Expenses ‐ Total (600,928) (632,309) (665,674) (701,165) 

Distillate Correction (150,728) (162,786) (175,809) (189,874) HFO Process & Heating (30,146) (32,557) (35,162) (37,975) Operating Engineer (164,324) (169,254) (174,332) (179,562) Chemical Consumption 0000

Scrubber Loads (75,364) (81,393) (87,904) (94,937) 

M&R Equip & Labor (180,367) (186,319) (192,467) (198,819) 

Savings ‐ Fuel Differential 3,768,194 4,069,650 4,395,222 4,746,839 NPV & IRR

Cash Flow (6,940,540) 3,167,266 3,437,341 3,729,548 4,045,674 

Discount Factor 1.0000 0.9091 0.8264 0.7513 0.6830 Present Value (6,940,540) 2,879,333 2,840,777 2,802,064 2,763,250 Net Present Value 20,109,656

Internal Rate of Return 52.62%

Exhaust Gas Cleaning SystemsOperators Guide

Life Cycle Cost ‐ Baseline Detail

Sheet 10 of 77

Fil
Inflation Baseline

Expenses BaselineCapital Cost ‐ Total

EquipmentAcquisition

Expenses ‐ Total

Distillate Correction

HFO Process & Heating

Operating EngineerChemical Consumption

Scrubber LoadsM&R Equip & Labor

Savings ‐ Fuel DifferentialNPV & IRR

Cash FlowDiscount FactorPresent ValueNet Present Value

Internal Rate of Return

Year

6 7 8 9 10

(779,151) (821,987) (867,634) (916,300) (968,204)

(221,469) (239,186) (258,321) (278,987) (301,306)

(44,294) (47,837) (51,664) (55,797) (60,261)

(190,497) (196,212) (202,098) (208,161) (214,406)

00000

(110,734) (119,593) (129,160) (139,493) (150,653)(212,157) (219,159) (226,391) (233,862) (241,579)

5,536,714 5,979,651 6,458,023 6,974,664 7,532,638

4,757,563 5,157,664 5,590,388 6,058,365 6,564,433

0.5645 0.5132 0.4665 0.4241 0.3855

2,685,520 2,646,697 2,607,957 2,569,338 2,530,873

Exhaust Gas Cleaning SystemsOperators Guide

Life Cycle Cost ‐ Baseline Detail

Sheet 11 of 77

Fil
Inflation Year

Expenses 01234

Capital Cost ‐ Total 0

Equipment 0Acquisition 0

Expenses ‐ Total (169,254) (174,332) (179,562) (184,948) 

Distillate Correction 0000HFO Process & Heating 0000Operating Engineer (169,254) (174,332) (179,562) (184,948) Chemical Consumption 0000

Scrubber Loads 0000

M&R Equip & Labor 0000

Savings ‐ Fuel Differential 0000

NPV & IRR

Cash Flow 0 (169,254) (174,332) (179,562) (184,948) 

Discount Factor 1.0000 0.9091 0.8264 0.7513 0.6830 Present Value 0 (153,867) (144,076) (134,907) (126,322) Net Present Value (1,165,101)

Internal Rate of Return NONE

Exhaust Gas Cleaning SystemsOperators Guide

Life Cycle Cost ‐ Baseline Detail

Sheet 12 of 77

Fil
Inflation

ExpensesCapital Cost ‐ Total

EquipmentAcquisition

Expenses ‐ Total

Distillate Correction

HFO Process & Heating

Operating EngineerChemical Consumption

Scrubber LoadsM&R Equip & Labor

Savings ‐ Fuel DifferentialNPV & IRR

Cash FlowDiscount FactorPresent ValueNet Present Value

Internal Rate of Return

Year

6 7 8 9 10

(196,212) (202,098) (208,161) (214,406) (220,838)

0000000000

(196,212) (202,098) (208,161) (214,406) (220,838)

00000000000000000000

(196,212) (202,098) (208,161) (214,406) (220,838)

0.5645 0.5132 0.4665 0.4241 0.3855

(110,756) (103,708) (97,109) (90,929) (85,143)

Exhaust Gas Cleaning SystemsOperators Guide

Life Cycle Cost ‐ Baseline Detail

Sheet 13 of 77

Fil
Ship/Route Pair

Containership

Alaska to Puget

Sound

Containership

Alaska to Puget

Sound

Containership

Alaska to Puget

Sound

Containe

Alaska to 

Soun

Scrubber Type Open Loop Closed Loop Hybrid Dry

Sensitivity Analysis Scrubber Types Open Loop Closed Loop Hybrid Dry

VARIABLES ‐ CONTROLLEDInvestment Terms

Life Cycle (# of Years) 10 10 10 10

Analysis Date (Today) (Year) 2011 2011 2011 2011

Scrubber Installation Date (Year) 2014 2014 2014 2014Discount Rate (%) 10.0% 10.0% 10.0% 10.0%

Capital Expense for Scrubber

Equipment (Today) (USD/One Time) $5,060,000 $6,180,000 $5,424,000 $5,120,

Engineering/Design (% Equip Cost) 7.0% 9.0% 9.0% 11.0%

Training/Documents (% Equip Cost) 2.0% 2.0% 2.0% 2.0%Install/Commission (% Equip Cost) 50.0% 65.0% 75.0% 85.0%

Operating Expense ‐ Annual

ECA Fuel Consumption (MT/Annual) 9,636 9,636 9,636 9,636

Chemical Consumption (% of Fuel Cost) 0.0% 3.0% 1.5% 3.0%

Scrubber Parasitic Loads (% of Fuel Cost) 2.0% 1.0% 1.5% 1.0%Distillate Calorie Correction (% of Fuel Cost) 4.0% 4.0% 4.0% 4.0%HFO Process and Heating (% of Fuel Cost) 0.8% 0.8% 0.8% 0.8%Operating Engineer (Today) (USD/Annual) $292,000 $292,000 $292,000 $292,0

Operating Engineer (% of Position) 50.0% 65.0% 65.0% 65.0%

M&R Equipment (% Equip Cost/Annual) 4.0% 4.0% 4.0% 4.0%

Variables ‐ Uncertain

Fuel Differential (Today) (USD/MT) $255.50 $255.50 $255.50 $255.5

Fuel/Chemical Escalation Rate (% ‐ Annual for Op Period) 8.0% 8.0% 8.0% 8.0%

Personnel Inflation Rate (% ‐ Annual for Op Period) 3.0% 3.0% 3.0% 3.0%Equipment Inflation Rate (% ‐ Annual for Op Period) 3.3% 3.3% 3.3% 3.3%

Exhaust Gas Cleaning SystemsOperators Guide

Life Cycle Cost ‐ EGCS Compare Summary

Sheet 14 of 77

Fil
Analysis Results ‐ Overview (Nearest $1,000)

Capital Cost (USD ‐ Year Zero Dollars) (8,868,000) (11,990,000) (11,121,000) (11,175,

Expenses ‐ Year One (USD ‐ Year One Dollars) (623,000) (790,000) (722,000) (742,00

Fuel Savings ‐ Year One (USD ‐ Year One Dollars) 3,350,000 3,350,000 3,350,000 3,350,0

Net Present Value (USD ‐ Present Dollars) 14,562,000 10,185,000 11,574,000 11,336,0

Internal Rate of Return (%) 36% 25% 28% 27%

Exhaust Gas Cleaning SystemsOperators Guide

Life Cycle Cost ‐ EGCS Compare Summary

Sheet 15 of 77

Fil
Scrubber Types Open Loop Year

01234

Capital Cost ‐ Total (8,868,468)

Equipment (5,577,653)Acquisition (3,290,815)

Expenses ‐ Total (622,559) (653,316) (685,929) (720,528) 

Distillate Correction (133,980) (144,699) (156,275) (168,777) HFO Process & Heating (26,796) (28,940) (31,255) (33,755) Operating Engineer (164,324) (169,254) (174,332) (179,562) Chemical Consumption 0000

Scrubber Loads (66,990) (72,349) (78,137) (84,388) 

M&R Equip & Labor (230,469) (238,074) (245,931) (254,046) 

Savings ‐ Fuel Differential 3,349,508 3,617,469 3,906,867 4,219,416 NPV & IRR

Cash Flow (8,868,468) 2,726,949 2,964,153 3,220,937 3,498,888 

Discount Factor 1.0000 0.9091 0.8264 0.7513 0.6830 Present Value (8,868,468) 2,479,044 2,449,713 2,419,938 2,389,787 Net Present Value (at Year 0) 14,562,028

Internal Rate of Return 36.17%

Exhaust Gas Cleaning SystemsOperators Guide

Life Cycle Cost ‐ EGCS Compare Details

Sheet 16 of 77

Fil
Scrubber Types Open Loop

Capital Cost ‐ Total

EquipmentAcquisition

Expenses ‐ Total

Distillate Correction

HFO Process & Heating

Operating EngineerChemical Consumption

Scrubber LoadsM&R Equip & Labor

Savings ‐ Fuel DifferentialNPV & IRR

Cash FlowDiscount FactorPresent ValueNet Present Value (at Year 0)

Internal Rate of Return

Year

6 7 8 9 10

(796,251) (837,685) (881,727) (928,564) (978,397)

(196,861) (212,610) (229,619) (247,988) (267,827)

(39,372) (42,522) (45,924) (49,598) (53,565)

(190,497) (196,212) (202,098) (208,161) (214,406)

00000

(98,431) (106,305) (114,809) (123,994) (133,914)

(271,090) (280,036) (289,277) (298,823) (308,684)

4,921,527 5,315,249 5,740,469 6,199,706 6,695,683

4,125,276 4,477,564 4,858,742 5,271,142 5,717,286

0.5645 0.5132 0.4665 0.4241 0.3855

2,328,611 2,297,698 2,266,639 2,235,479 2,204,261

Exhaust Gas Cleaning SystemsOperators Guide

Life Cycle Cost ‐ EGCS Compare Details

Sheet 17 of 77

Fil
Scrubber Types Closed Loop Year

01234

Capital Cost ‐ Total (11,989,529)

Equipment (6,812,232)Acquisition (5,177,296)

Expenses ‐ Total (789,860) (829,138) (870,801) (915,016) 

Distillate Correction (133,980) (144,699) (156,275) (168,777) HFO Process & Heating (26,796) (28,940) (31,255) (33,755) Operating Engineer (213,622) (220,030) (226,631) (233,430) Chemical Consumption (100,485) (108,524) (117,206) (126,582) Scrubber Loads (33,495) (36,175) (39,069) (42,194) M&R Equip & Labor (281,481) (290,770) (300,366) (310,278) 

Savings ‐ Fuel Differential 3,349,508 3,617,469 3,906,867 4,219,416 NPV & IRR

Cash Flow (11,989,529) 2,559,649 2,788,331 3,036,065 3,304,399 

Discount Factor 1.0000 0.9091 0.8264 0.7513 0.6830 Present Value (11,989,529) 2,326,953 2,304,406 2,281,041 2,256,949 

Net Present Value 10,184,863

Internal Rate of Return 24.71%

Exhaust Gas Cleaning SystemsOperators Guide

Life Cycle Cost ‐ EGCS Compare Details

Sheet 18 of 77

Fil
Scrubber Types Closed Loop

Capital Cost ‐ Total

EquipmentAcquisition

Expenses ‐ Total

Distillate Correction

HFO Process & Heating

Operating EngineerChemical Consumption

Scrubber LoadsM&R Equip & Labor

Savings ‐ Fuel DifferentialNPV & IRR

Cash FlowDiscount FactorPresent ValueNet Present Value

Internal Rate of Return

Year

6 7 8 9 10

(1,011,834) (1,064,837) (1,121,196) (1,181,149) (1,244,958)

(196,861) (212,610) (229,619) (247,988) (267,827)

(39,372) (42,522) (45,924) (49,598) (53,565)

(247,646) (255,075) (262,728) (270,609) (278,728)(147,646) (159,457) (172,214) (185,991) (200,870)

(49,215) (53,152) (57,405) (61,997) (66,957)

(331,094) (342,020) (353,307) (364,966) (377,010)

4,921,527 5,315,249 5,740,469 6,199,706 6,695,683

3,909,692 4,250,411 4,619,273 5,018,557 5,450,725

0.5645 0.5132 0.4665 0.4241 0.3855

2,206,919 2,181,133 2,154,925 2,128,358 2,101,491

Exhaust Gas Cleaning SystemsOperators Guide

Life Cycle Cost ‐ EGCS Compare Details

Sheet 19 of 77

Fil
Scrubber Types Hybrid Year

01234

Capital Cost ‐ Total (11,120,738)

Equipment (5,978,891)Acquisition (5,141,846)

Expenses ‐ Total (721,931) (757,393) (794,989) (834,866) 

Distillate Correction (133,980) (144,699) (156,275) (168,777) HFO Process & Heating (26,796) (28,940) (31,255) (33,755) Operating Engineer (213,622) (220,030) (226,631) (233,430) Chemical Consumption (50,243) (54,262) (58,603) (63,291) Scrubber Loads (50,243) (54,262) (58,603) (63,291) M&R Equip & Labor (247,048) (255,200) (263,622) (272,321) 

Savings ‐ Fuel Differential 3,349,508 3,617,469 3,906,867 4,219,416 NPV & IRR

Cash Flow (11,120,738) 2,627,577 2,860,076 3,111,878 3,384,550 

Discount Factor 1.0000 0.9091 0.8264 0.7513 0.6830 Present Value (11,120,738) 2,388,707 2,363,699 2,338,000 2,311,693 

Net Present Value 11,574,199

Internal Rate of Return 27.61%

Exhaust Gas Cleaning SystemsOperators Guide

Life Cycle Cost ‐ EGCS Compare Details

Sheet 20 of 77

Fil
Scrubber Types Hybrid

Capital Cost ‐ Total

EquipmentAcquisition

Expenses ‐ Total

Distillate Correction

HFO Process & Heating

Operating EngineerChemical Consumption

Scrubber LoadsM&R Equip & Labor

Savings ‐ Fuel DifferentialNPV & IRR

Cash FlowDiscount FactorPresent ValueNet Present Value

Internal Rate of Return

Year

6 7 8 9 10

(922,116) (969,846) (1,020,571) (1,074,506) (1,131,881)

(196,861) (212,610) (229,619) (247,988) (267,827)

(39,372) (42,522) (45,924) (49,598) (53,565)

(247,646) (255,075) (262,728) (270,609) (278,728)

(73,823) (79,729) (86,107) (92,996) (100,435)(73,823) (79,729) (86,107) (92,996) (100,435)

(290,591) (300,181) (310,087) (320,320) (330,890)

4,921,527 5,315,249 5,740,469 6,199,706 6,695,683

3,999,410 4,345,403 4,719,898 5,125,200 5,563,802

0.5645 0.5132 0.4665 0.4241 0.3855

2,257,563 2,229,879 2,201,867 2,173,585 2,145,086

Exhaust Gas Cleaning SystemsOperators Guide

Life Cycle Cost ‐ EGCS Compare Details

Sheet 21 of 77

Fil
Scrubber Types Dry Year

01234

Capital Cost ‐ Total (11,174,706)

Equipment (5,643,791)Acquisition (5,530,915)

Expenses ‐ Total (741,580) (779,265) (819,282) (861,797) 

Distillate Correction (133,980) (144,699) (156,275) (168,777) HFO Process & Heating (26,796) (28,940) (31,255) (33,755) Operating Engineer (213,622) (220,030) (226,631) (233,430) Chemical Consumption (100,485) (108,524) (117,206) (126,582) Scrubber Loads (33,495) (36,175) (39,069) (42,194) M&R Equip & Labor (233,201) (240,897) (248,847) (257,059) 

Savings ‐ Fuel Differential 3,349,508 3,617,469 3,906,867 4,219,416 NPV & IRR

Cash Flow (11,174,706) 2,607,929 2,838,204 3,087,584 3,357,619 

Discount Factor 1.0000 0.9091 0.8264 0.7513 0.6830 Present Value (11,174,706) 2,370,844 2,345,624 2,319,748 2,293,299 

Net Present Value 11,335,895

Internal Rate of Return 27.22%

Exhaust Gas Cleaning SystemsOperators Guide

Life Cycle Cost ‐ EGCS Compare Details

Sheet 22 of 77

Fil
Scrubber Types Dry

Capital Cost ‐ Total

EquipmentAcquisition

Expenses ‐ Total

Distillate Correction

HFO Process & Heating

Operating EngineerChemical Consumption

Scrubber LoadsM&R Equip & Labor

Savings ‐ Fuel DifferentialNPV & IRR

Cash FlowDiscount FactorPresent ValueNet Present Value

Internal Rate of Return

Year

6 7 8 9 10

(955,045) (1,006,174) (1,060,596) (1,118,550) (1,180,292)

(196,861) (212,610) (229,619) (247,988) (267,827)

(39,372) (42,522) (45,924) (49,598) (53,565)

(247,646) (255,075) (262,728) (270,609) (278,728)(147,646) (159,457) (172,214) (185,991) (200,870)

(49,215) (53,152) (57,405) (61,997) (66,957)

(274,304) (283,356) (292,707) (302,367) (312,345)

4,921,527 5,315,249 5,740,469 6,199,706 6,695,683

3,966,482 4,309,075 4,679,873 5,081,156 5,515,390

0.5645 0.5132 0.4665 0.4241 0.3855

2,238,976 2,211,237 2,183,195 2,154,906 2,126,422

Exhaust Gas Cleaning SystemsOperators Guide

Life Cycle Cost ‐ EGCS Compare Details

Sheet 23 of 77

Fil
Ship/Route Pair

Containership

Alaska to Puget

Sound

Containership

Alaska to Puget

Sound

Containership

Alaska to Puget

Sound

Containe

Alaska to 

Soun

Scrubber Type Open Loop Open Loop Open Loop Open Lo

Sensitivity Analysis Fuel Consumption 21% 50% 75% 100%

VARIABLES ‐ CONTROLLED

Investment Terms

Life Cycle (# of Years) 10 10 10 10

Analysis Date (Today) (Year) 2011 2011 2011 2011

Scrubber Installation Date (Year) 2014 2014 2014 2014Discount Rate (%) 10.0% 10.0% 10.0% 10.0%

Capital Expense for Scrubber

Equipment (Today) (USD/One Time) $5,060,000 $5,060,000 $5,060,000 $5,060,

Engineering/Design (% Equip Cost) 7.0% 7.0% 7.0% 7.0%

Training/Documents (% Equip Cost) 2.0% 2.0% 2.0% 2.0%Install/Commission (% Equip Cost) 50.0% 50.0% 50.0% 50.0%

Operating Expense ‐ Annual

ECA Fuel Consumption (MT/Annual) 4,000 9,523 14,285 19,04

Chemical Consumption (% of Fuel Cost) 0.0% 0.0% 0.0% 0.0%

Scrubber Parasitic Loads (% of Fuel Cost) 2.0% 2.0% 2.0% 2.0%Distillate Calorie Correction (% of Fuel Cost) 4.0% 4.0% 4.0% 4.0%HFO Process and Heating (% of Fuel Cost) 0.8% 0.8% 0.8% 0.8%Operating Engineer (Today) (USD/Annual) $292,000 $292,000 $292,000 $292,0

Operating Engineer (% of Position) 50.0% 50.0% 50.0% 50.0%

M&R Equipment (% Equip Cost/Annual) 4.0% 4.0% 4.0% 4.0%

Variables ‐ Uncertain

Fuel Differential (Today) (USD/MT) $255.50 $255.50 $255.50 $255.5

Fuel/Chemical Escalation Rate (% ‐ Annual for Op Period) 8.0% 8.0% 8.0% 8.0%

Personnel Inflation Rate (% ‐ Annual for Op Period) 3.0% 3.0% 3.0% 3.0%Equipment Inflation Rate (% ‐ Annual for Op Period) 3.3% 3.3% 3.3% 3.3%

Exhaust Gas Cleaning SystemsOperators Guide

Life Cycle Cost ‐ Fuel Consumption Summary

Sheet 24 of 77

Fil
Analysis Results ‐ Overview (Nearest $1,000)

Capital Cost (USD ‐ Year Zero Dollars) (8,868,000) (8,868,000) (8,868,000) (8,868,0

Expenses ‐ Year One (USD ‐ Year One Dollars) (489,000) (620,000) (732,000) (845,00

Fuel Savings ‐ Year One (USD ‐ Year One Dollars) 1,390,000 3,310,000 4,965,000 6,621,0

Net Present Value (USD ‐ Present Dollars) (743,000) 14,256,000 27,186,000 40,116,0

Internal Rate of Return (%) 8% 36% 55% 73%

Exhaust Gas Cleaning SystemsOperators Guide

Life Cycle Cost ‐ Fuel Consumption Summary

Sheet 25 of 77

Fil
Fuel Consumption 0.21 Year

01234

Capital Cost ‐ Total (8,868,468)

Equipment (5,577,653)Acquisition (3,290,815)

Expenses ‐ Total (489,336) (509,434) (530,537) (552,704) 

Distillate Correction (55,613) (60,062) (64,867) (70,057) 

HFO Process & Heating (11,123) (12,012) (12,973) (14,011) Operating Engineer (164,324) (169,254) (174,332) (179,562) Chemical Consumption 0000

Scrubber Loads (27,807) (30,031) (32,434) (35,028) 

M&R Equip & Labor (230,469) (238,074) (245,931) (254,046) 

Savings ‐ Fuel Differential 1,390,333 1,501,560 1,621,684 1,751,419 NPV & IRR

Cash Flow (8,868,468) 900,997 992,125 1,091,148 1,198,715 Discount Factor 1.0000 0.9091 0.8264 0.7513 0.6830 Present Value (8,868,468) 819,089 819,938 819,795 818,738 

Net Present Value (at Year 0) (743,184)

Internal Rate of Return 8.28%

Exhaust Gas Cleaning SystemsOperators Guide

Life Cycle Cost ‐ Fuel Consumption Details

Sheet 26 of 77

Fil
Fuel Consumption 0.21

Capital Cost ‐ Total

EquipmentAcquisition

Expenses ‐ Total

Distillate Correction

HFO Process & Heating

Operating EngineerChemical Consumption

Scrubber LoadsM&R Equip & Labor

Savings ‐ Fuel DifferentialNPV & IRR

Cash FlowDiscount FactorPresent ValueNet Present Value (at Year 0)

Internal Rate of Return

Year

6 7 8 9 10

(600,501) (626,275) (653,405) (681,976) (712,082)

(81,714) (88,251) (95,311) (102,936) (111,171)(16,343) (17,650) (19,062) (20,587) (22,234)

(190,497) (196,212) (202,098) (208,161) (214,406)

00000

(40,857) (44,126) (47,656) (51,468) (55,586)

(271,090) (280,036) (289,277) (298,823) (308,684)

2,042,855 2,206,284 2,382,786 2,573,409 2,779,282

1,442,354 1,580,009 1,729,382 1,891,433 2,067,201

0.5645 0.5132 0.4665 0.4241 0.3855

814,171 810,794 806,769 802,152 796,995

Exhaust Gas Cleaning SystemsOperators Guide

Life Cycle Cost ‐ Fuel Consumption Details

Sheet 27 of 77

Fil
Fuel Consumption 0.5 Year

01234

Capital Cost ‐ Total (8,868,468)

Equipment (5,577,653)Acquisition (3,290,815)

Expenses ‐ Total (619,894) (650,438) (682,821) (717,171) 

Distillate Correction (132,413) (143,006) (154,446) (166,802) HFO Process & Heating (26,483) (28,601) (30,889) (33,360) Operating Engineer (164,324) (169,254) (174,332) (179,562) Chemical Consumption 0000

Scrubber Loads (66,206) (71,503) (77,223) (83,401) 

M&R Equip & Labor (230,469) (238,074) (245,931) (254,046) 

Savings ‐ Fuel Differential 3,310,317 3,575,142 3,861,153 4,170,046 NPV & IRR

Cash Flow (8,868,468) 2,690,422 2,924,704 3,178,333 3,452,875 

Discount Factor 1.0000 0.9091 0.8264 0.7513 0.6830 Present Value (8,868,468) 2,445,838 2,417,111 2,387,928 2,358,360 Net Present Value 14,255,860

Internal Rate of Return 35.69%

Exhaust Gas Cleaning SystemsOperators Guide

Life Cycle Cost ‐ Fuel Consumption Details

Sheet 28 of 77

Fil
Fuel Consumption 0.5

Capital Cost ‐ Total

EquipmentAcquisition

Expenses ‐ Total

Distillate Correction

HFO Process & Heating

Operating EngineerChemical Consumption

Scrubber LoadsM&R Equip & Labor

Savings ‐ Fuel DifferentialNPV & IRR

Cash FlowDiscount FactorPresent ValueNet Present Value

Internal Rate of Return

Year

6 7 8 9 10

(792,335) (833,456) (877,160) (923,632) (973,069)

(194,558) (210,122) (226,932) (245,087) (264,694)

(38,912) (42,024) (45,386) (49,017) (52,939)

(190,497) (196,212) (202,098) (208,161) (214,406)

00000

(97,279) (105,061) (113,466) (122,543) (132,347)

(271,090) (280,036) (289,277) (298,823) (308,684)

4,863,941 5,253,056 5,673,301 6,127,165 6,617,338

4,071,606 4,419,601 4,796,141 5,203,534 5,644,269

0.5645 0.5132 0.4665 0.4241 0.3855

2,298,316 2,267,954 2,237,435 2,206,806 2,176,110

Exhaust Gas Cleaning SystemsOperators Guide

Life Cycle Cost ‐ Fuel Consumption Details

Sheet 29 of 77

Fil
Fuel Consumption 0.75 Year

01234

Capital Cost ‐ Total (8,868,468)

Equipment (5,577,653)Acquisition (3,290,815)

Expenses ‐ Total (732,445) (771,993) (814,100) (858,952) 

Distillate Correction (198,619) (214,509) (231,669) (250,203) HFO Process & Heating (39,724) (42,902) (46,334) (50,041) Operating Engineer (164,324) (169,254) (174,332) (179,562) Chemical Consumption 0000

Scrubber Loads (99,309) (107,254) (115,835) (125,101) 

M&R Equip & Labor (230,469) (238,074) (245,931) (254,046) 

Savings ‐ Fuel Differential 4,965,475 5,362,713 5,791,730 6,255,068 NPV & IRR

Cash Flow (8,868,468) 4,233,030 4,590,720 4,977,630 5,396,116 

Discount Factor 1.0000 0.9091 0.8264 0.7513 0.6830 Present Value (8,868,468) 3,848,209 3,793,984 3,739,767 3,685,620 Net Present Value 27,186,070

Internal Rate of Return 54.79%

Exhaust Gas Cleaning SystemsOperators Guide

Life Cycle Cost ‐ Fuel Consumption Details

Sheet 30 of 77

Fil
Fuel Consumption 0.75

Capital Cost ‐ Total

EquipmentAcquisition

Expenses ‐ Total

Distillate Correction

HFO Process & Heating

Operating EngineerChemical Consumption

Scrubber LoadsM&R Equip & Labor

Savings ‐ Fuel DifferentialNPV & IRR

Cash FlowDiscount FactorPresent ValueNet Present Value

Internal Rate of Return

Year

6 7 8 9 10

(957,709) (1,012,059) (1,070,052) (1,131,955) (1,198,059)

(291,836) (315,183) (340,398) (367,630) (397,040)

(58,367) (63,037) (68,080) (73,526) (79,408)

(190,497) (196,212) (202,098) (208,161) (214,406)

00000

(145,918) (157,592) (170,199) (183,815) (198,520)(271,090) (280,036) (289,277) (298,823) (308,684)

7,295,912 7,879,585 8,509,951 9,190,748 9,926,007

6,338,203 6,867,525 7,439,900 8,058,792 8,727,949

0.5645 0.5132 0.4665 0.4241 0.3855

3,577,750 3,524,126 3,470,768 3,417,715 3,365,002

Exhaust Gas Cleaning SystemsOperators Guide

Life Cycle Cost ‐ Fuel Consumption Details

Sheet 31 of 77

Fil
Fuel Consumption 1 Year

01234

Capital Cost ‐ Total (8,868,468)

Equipment (5,577,653)Acquisition (3,290,815)

Expenses ‐ Total (844,996) (893,547) (945,379) (1,000,734) 

Distillate Correction (264,825) (286,011) (308,892) (333,604) HFO Process & Heating (52,965) (57,202) (61,778) (66,721) Operating Engineer (164,324) (169,254) (174,332) (179,562) Chemical Consumption 0000

Scrubber Loads (132,413) (143,006) (154,446) (166,802) 

M&R Equip & Labor (230,469) (238,074) (245,931) (254,046) 

Savings ‐ Fuel Differential 6,620,633 7,150,284 7,722,307 8,340,091 NPV & IRR

Cash Flow (8,868,468) 5,775,637 6,256,737 6,776,928 7,339,357 

Discount Factor 1.0000 0.9091 0.8264 0.7513 0.6830 Present Value (8,868,468) 5,250,579 5,170,857 5,091,606 5,012,880 Net Present Value 40,116,280

Internal Rate of Return 72.83%

Exhaust Gas Cleaning SystemsOperators Guide

Life Cycle Cost ‐ Fuel Consumption Details

Sheet 32 of 77

Fil
Fuel Consumption 1

Capital Cost ‐ Total

EquipmentAcquisition

Expenses ‐ Total

Distillate Correction

HFO Process & Heating

Operating EngineerChemical Consumption

Scrubber LoadsM&R Equip & Labor

Savings ‐ Fuel DifferentialNPV & IRR

Cash FlowDiscount FactorPresent ValueNet Present Value

Internal Rate of Return

Year

6 7 8 9 10

(1,123,083) (1,190,663) (1,262,944) (1,340,279) (1,423,048)

(389,115) (420,245) (453,864) (490,173) (529,387)

(77,823) (84,049) (90,773) (98,035) (105,877)

(190,497) (196,212) (202,098) (208,161) (214,406)

00000

(194,558) (210,122) (226,932) (245,087) (264,694)(271,090) (280,036) (289,277) (298,823) (308,684)

9,727,882 10,506,113 11,346,602 12,254,330 13,234,677

8,604,800 9,315,450 10,083,658 10,914,051 11,811,628

0.5645 0.5132 0.4665 0.4241 0.3855

4,857,185 4,780,299 4,704,101 4,628,623 4,553,894

Exhaust Gas Cleaning SystemsOperators Guide

Life Cycle Cost ‐ Fuel Consumption Details

Sheet 33 of 77

Fil
Ship/Route Pair

Containership

Alaska to Puget

Sound

Containership

Alaska to Puget

Sound

Containership

Alaska to Puget

Sound

Containe

Alaska to 

Soun

Scrubber Type Open Loop Open Loop Open Loop Open Lo

Sensitivity Analysis Inflation Low Moderate Predicted High

Fuel Escalation Low Moderate Predicted High

VARIABLES ‐ CONTROLLEDInvestment Terms

Life Cycle (# of Years) 10 10 10 10

Analysis Date (Today) (Year) 2011 2011 2011 2011

Scrubber Installation Date (Year) 2014 2014 2014 2014Discount Rate (%) 10.0% 10.0% 10.0% 10.0%

Capital Expense for Scrubber

Equipment (Today) (USD/One Time) $5,060,000 $5,060,000 $5,060,000 $5,060,

Engineering/Design (% Equip Cost) 7.0% 7.0% 7.0% 7.0%

Training/Documents (% Equip Cost) 2.0% 2.0% 2.0% 2.0%Install/Commission (% Equip Cost) 50.0% 50.0% 50.0% 50.0%

Operating Expense ‐ Annual

ECA Fuel Consumption (MT/Annual) 9,636 9,636 9,636 9,636

Chemical Consumption (% of Fuel Cost) 0.0% 0.0% 0.0% 0.0%

Scrubber Parasitic Loads (% of Fuel Cost) 2.0% 2.0% 2.0% 2.0%Distillate Calorie Correction (% of Fuel Cost) 4.0% 4.0% 4.0% 4.0%HFO Process and Heating (% of Fuel Cost) 0.8% 0.8% 0.8% 0.8%Operating Engineer (Today) (USD/Annual) $292,000 $292,000 $292,000 $292,0

Operating Engineer (% of Position) 50.0% 50.0% 50.0% 50.0%

M&R Equipment (% Equip Cost/Annual) 4.0% 4.0% 4.0% 4.0%

Variables ‐ Uncertain

Fuel Differential (Today) (USD/MT) $255.50 $255.50 $255.50 $255.5

Fuel/Chemical Escalation Rate (% ‐ Annual for Op Period) 2.0% 5.0% 8.0% 11.0%

Personnel Inflation Rate (% ‐ Annual for Op Period) 1.0% 2.0% 3.0% 5.0%Equipment Inflation Rate (% ‐ Annual for Op Period) 1.0% 2.0% 3.3% 5.0%

Exhaust Gas Cleaning SystemsOperators Guide

Life Cycle Cost ‐ Inflation Summary

Sheet 34 of 77

Fil
Analysis Results ‐ Overview (Nearest $1,000)

Capital Cost (USD ‐ Year Zero Dollars) (8,289,000) (8,538,000) (8,868,000) (8,669,0

Expenses ‐ Year One (USD ‐ Year One Dollars) (544,000) (581,000) (623,000) (678,00

Fuel Savings ‐ Year One (USD ‐ Year One Dollars) 2,665,000 2,993,000 3,350,000 3,737,0

Net Present Value (USD ‐ Present Dollars) 5,854,000 9,714,000 14,562,000 21,174,0Internal Rate of Return (%) 24% 30% 36% 44%

11.52016187 14.46884962 17.36018386 0.3464

Exhaust Gas Cleaning SystemsOperators Guide

Life Cycle Cost ‐ Inflation Summary

Sheet 35 of 77

Fil
Inflation Low Year

Fuel Escalation Low 01234

Capital Cost ‐ Total (8,289,184)

Equipment (5,213,323)Acquisition (3,075,861)

Expenses ‐ Total (543,762) (551,012) (558,370) (565,839) 

Distillate Correction (106,597) (108,729) (110,904) (113,122) HFO Process & Heating (21,319) (21,746) (22,181) (22,624) Operating Engineer (151,928) (153,447) (154,982) (156,532) Chemical Consumption 0000

Scrubber Loads (53,299) (54,365) (55,452) (56,561) 

M&R Equip & Labor (210,618) (212,724) (214,852) (217,000) 

Savings ‐ Fuel Differential 2,664,936 2,718,234 2,772,599 2,828,051 NPV & IRR

Cash Flow (8,289,184) 2,121,174 2,167,223 2,214,229 2,262,212 

Discount Factor 1.0000 0.9091 0.8264 0.7513 0.6830 Present Value (8,289,184) 1,928,340 1,791,093 1,663,583 1,545,121 Net Present Value (at Year 0) 5,853,509

Internal Rate of Return 24.10%

Exhaust Gas Cleaning SystemsOperators Guide

Life Cycle Cost ‐ Inflation Details

Sheet 36 of 77

Fil
Inflation Low

Fuel Escalation LowCapital Cost ‐ Total

EquipmentAcquisition

Expenses ‐ Total

Distillate Correction

HFO Process & Heating

Operating EngineerChemical Consumption

Scrubber LoadsM&R Equip & Labor

Savings ‐ Fuel DifferentialNPV & IRR

Cash FlowDiscount FactorPresent ValueNet Present Value (at Year 0)

Internal Rate of Return

Year

6 7 8 9 10

(581,117) (588,929) (596,859) (604,909) (613,081)

(117,692) (120,046) (122,447) (124,896) (127,394)

(23,538) (24,009) (24,489) (24,979) (25,479)

(159,678) (161,275) (162,888) (164,516) (166,162)

00000

(58,846) (60,023) (61,223) (62,448) (63,697)

(221,362) (223,576) (225,811) (228,069) (230,350)

2,942,304 3,001,150 3,061,173 3,122,397 3,184,845

2,361,188 2,412,222 2,464,315 2,517,488 2,571,764

0.5645 0.5132 0.4665 0.4241 0.3855

1,332,829 1,237,851 1,149,621 1,067,661 991,526

Exhaust Gas Cleaning SystemsOperators Guide

Life Cycle Cost ‐ Inflation Details

Sheet 37 of 77

Fil
Inflation Moderate Year

Fuel Escalation Moderate 01234

Capital Cost ‐ Total (8,537,843)

Equipment (5,369,712)Acquisition (3,168,130)

Expenses ‐ Total (580,614) (598,331) (616,707) (635,772) 

Distillate Correction (119,703) (125,688) (131,972) (138,571) HFO Process & Heating (23,941) (25,138) (26,394) (27,714) Operating Engineer (158,035) (161,196) (164,420) (167,708) Chemical Consumption 0000

Scrubber Loads (59,851) (62,844) (65,986) (69,285) 

M&R Equip & Labor (219,084) (223,466) (227,935) (232,494) 

Savings ‐ Fuel Differential 2,992,563 3,142,191 3,299,300 3,464,265 NPV & IRR

Cash Flow (8,537,843) 2,411,949 2,543,860 2,682,593 2,828,493 

Discount Factor 1.0000 0.9091 0.8264 0.7513 0.6830 Present Value (8,537,843) 2,192,681 2,102,364 2,015,472 1,931,899 Net Present Value 9,713,769

Internal Rate of Return 30.28%

Exhaust Gas Cleaning SystemsOperators Guide

Life Cycle Cost ‐ Inflation Details

Sheet 38 of 77

Fil
Inflation Moderate

Fuel Escalation ModerateCapital Cost ‐ Total

EquipmentAcquisition

Expenses ‐ Total

Distillate Correction

HFO Process & Heating

Operating EngineerChemical Consumption

Scrubber LoadsM&R Equip & Labor

Savings ‐ Fuel DifferentialNPV & IRR

Cash FlowDiscount FactorPresent ValueNet Present Value

Internal Rate of Return

Year

6 7 8 9 10

(676,086) (697,399) (719,528) (742,509) (766,379)

(152,774) (160,413) (168,433) (176,855) (185,698)

(30,555) (32,083) (33,687) (35,371) (37,140)

(174,484) (177,973) (181,533) (185,163) (188,867)

00000

(76,387) (80,206) (84,217) (88,428) (92,849)

(241,887) (246,724) (251,659) (256,692) (261,826)

3,819,352 4,010,320 4,210,836 4,421,378 4,642,447

3,143,266 3,312,921 3,491,308 3,678,869 3,876,068

0.5645 0.5132 0.4665 0.4241 0.3855

1,774,292 1,700,052 1,628,721 1,560,199 1,494,392

Exhaust Gas Cleaning SystemsOperators Guide

Life Cycle Cost ‐ Inflation Details

Sheet 39 of 77

Fil
Inflation Predicted Year

Fuel Escalation Predicted 01234

Capital Cost ‐ Total (8,868,468)

Equipment (5,577,653)Acquisition (3,290,815)

Expenses ‐ Total (622,559) (653,316) (685,929) (720,528) 

Distillate Correction (133,980) (144,699) (156,275) (168,777) HFO Process & Heating (26,796) (28,940) (31,255) (33,755) Operating Engineer (164,324) (169,254) (174,332) (179,562) Chemical Consumption 0000

Scrubber Loads (66,990) (72,349) (78,137) (84,388) 

M&R Equip & Labor (230,469) (238,074) (245,931) (254,046) 

Savings ‐ Fuel Differential 3,349,508 3,617,469 3,906,867 4,219,416 NPV & IRR

Cash Flow (8,868,468) 2,726,949 2,964,153 3,220,937 3,498,888 

Discount Factor 1.0000 0.9091 0.8264 0.7513 0.6830 Present Value (8,868,468) 2,479,044 2,449,713 2,419,938 2,389,787 Net Present Value 14,562,028

Internal Rate of Return 36.17%

Exhaust Gas Cleaning SystemsOperators Guide

Life Cycle Cost ‐ Inflation Details

Sheet 40 of 77

Fil
Inflation Predicted

Fuel Escalation PredictedCapital Cost ‐ Total

EquipmentAcquisition

Expenses ‐ Total

Distillate Correction

HFO Process & Heating

Operating EngineerChemical Consumption

Scrubber LoadsM&R Equip & Labor

Savings ‐ Fuel DifferentialNPV & IRR

Cash FlowDiscount FactorPresent ValueNet Present Value

Internal Rate of Return

Year

6 7 8 9 10

(796,251) (837,685) (881,727) (928,564) (978,397)

(196,861) (212,610) (229,619) (247,988) (267,827)

(39,372) (42,522) (45,924) (49,598) (53,565)

(190,497) (196,212) (202,098) (208,161) (214,406)

00000

(98,431) (106,305) (114,809) (123,994) (133,914)

(271,090) (280,036) (289,277) (298,823) (308,684)

4,921,527 5,315,249 5,740,469 6,199,706 6,695,683

4,125,276 4,477,564 4,858,742 5,271,142 5,717,286

0.5645 0.5132 0.4665 0.4241 0.3855

2,328,611 2,297,698 2,266,639 2,235,479 2,204,261

Exhaust Gas Cleaning SystemsOperators Guide

Life Cycle Cost ‐ Inflation Details

Sheet 41 of 77

Fil
Inflation High Year

Fuel Escalation High 01234

Capital Cost ‐ Total (8,669,297)

Equipment (5,213,323)Acquisition (3,455,974)

Expenses ‐ Total (677,630) (726,761) (780,025) (837,815) 

Distillate Correction (149,499) (165,944) (184,198) (204,459) HFO Process & Heating (29,900) (33,189) (36,840) (40,892) Operating Engineer (177,464) (186,337) (195,654) (205,437) Chemical Consumption 0000

Scrubber Loads (74,749) (82,972) (92,099) (102,230) 

M&R Equip & Labor (246,018) (258,319) (271,235) (284,797) 

Savings ‐ Fuel Differential 3,737,472 4,148,594 4,604,939 5,111,483 NPV & IRR

Cash Flow (8,669,297) 3,059,842 3,421,833 3,824,914 4,273,668 

Discount Factor 1.0000 0.9091 0.8264 0.7513 0.6830 Present Value (8,669,297) 2,781,674 2,827,961 2,873,715 2,918,973 Net Present Value 21,174,017

Internal Rate of Return 44.30%

Exhaust Gas Cleaning SystemsOperators Guide

Life Cycle Cost ‐ Inflation Details

Sheet 42 of 77

Fil
Inflation High

Fuel Escalation HighCapital Cost ‐ Total

EquipmentAcquisition

Expenses ‐ Total

Distillate Correction

HFO Process & Heating

Operating EngineerChemical Consumption

Scrubber LoadsM&R Equip & Labor

Savings ‐ Fuel DifferentialNPV & IRR

Cash FlowDiscount FactorPresent ValueNet Present Value

Internal Rate of Return

Year

6 7 8 9 10

(968,737) (1,042,869) (1,123,534) (1,211,370) (1,307,080)

(251,914) (279,625) (310,384) (344,526) (382,424)

(50,383) (55,925) (62,077) (68,905) (76,485)

(226,494) (237,819) (249,710) (262,195) (275,305)

00000

(125,957) (139,812) (155,192) (172,263) (191,212)(313,989) (329,688) (346,173) (363,481) (381,655)

6,297,858 6,990,622 7,759,591 8,613,146 9,560,592

5,329,121 5,947,753 6,636,056 7,401,775 8,253,511

0.5645 0.5132 0.4665 0.4241 0.3855

3,008,150 3,052,138 3,095,769 3,139,075 3,182,086

Exhaust Gas Cleaning SystemsOperators Guide

Life Cycle Cost ‐ Inflation Details

Sheet 43 of 77

Fil
Ship/Route Pair

Containership

Alaska to Puget

Sound

Containership

Alaska to Puget

Sound

Containership

Alaska to Puget

Sound

Containe

Alaska to 

Soun

Scrubber Type Open Loop Open Loop Open Loop Open Lo

Sensitivity Analysis Opeating Years Minimum 10 15 20

VARIABLES ‐ CONTROLLEDInvestment Terms

Life Cycle (# of Years) 4 10 15 20

Analysis Date (Today) (Year) 2011 2011 2011 2011

Scrubber Installation Date (Year) 2014 2014 2014 2014Discount Rate (%) 10.0% 10.0% 10.0% 10.0%

Capital Expense for Scrubber

Equipment (Today) (USD/One Time) $5,060,000 $5,060,000 $5,060,000 $5,060,

Engineering/Design (% Equip Cost) 7.0% 7.0% 7.0% 7.0%

Training/Documents (% Equip Cost) 2.0% 2.0% 2.0% 2.0%Install/Commission (% Equip Cost) 50.0% 50.0% 50.0% 50.0%

Operating Expense ‐ Annual

ECA Fuel Consumption (MT/Annual) 9,636 9,636 9,636 9,636

Chemical Consumption (% of Fuel Cost) 0.0% 0.0% 0.0% 0.0%

Scrubber Parasitic Loads (% of Fuel Cost) 2.0% 2.0% 2.0% 2.0%Distillate Calorie Correction (% of Fuel Cost) 4.0% 4.0% 4.0% 4.0%HFO Process and Heating (% of Fuel Cost) 0.8% 0.8% 0.8% 0.8%Operating Engineer (Today) (USD/Annual) $292,000 $292,000 $292,000 $292,0

Operating Engineer (% of Position) 50.0% 50.0% 50.0% 50.0%

M&R Equipment (% Equip Cost/Annual) 4.0% 4.0% 4.0% 4.0%

Variables ‐ Uncertain

Fuel Differential (Today) (USD/MT) $255.50 $255.50 $255.50 $255.5

Fuel/Chemical Escalation Rate (% ‐ Annual for Op Period) 8.0% 8.0% 8.0% 8.0%

Personnel Inflation Rate (% ‐ Annual for Op Period) 3.0% 3.0% 3.0% 3.0%Equipment Inflation Rate (% ‐ Annual for Op Period) 3.3% 3.3% 3.3% 3.3%

Exhaust Gas Cleaning SystemsOperators Guide

Life Cycle Cost ‐ Op Years Summary

Sheet 44 of 77

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Analysis Results ‐ Overview (Nearest $1,000)

Capital Cost (USD ‐ Year Zero Dollars) (8,868,000) (8,868,000) (8,868,000) (8,868,0

Expenses ‐ Year One (USD ‐ Year One Dollars) (623,000) (623,000) (623,000) (623,00

Fuel Savings ‐ Year One (USD ‐ Year One Dollars) 3,350,000 3,350,000 3,350,000 3,350,0

Net Present Value (USD ‐ Present Dollars) (1,520,000) 14,562,000 14,562,000 14,562,0

Internal Rate of Return (%) 0% 36% 36% 36%

Exhaust Gas Cleaning SystemsOperators Guide

Life Cycle Cost ‐ Op Years Summary

Sheet 45 of 77

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Opeating Years Minimum Year

01234

Capital Cost ‐ Total (8,868,468)

Equipment (5,577,653)Acquisition (3,290,815)

Expenses ‐ Total (622,559) (653,316) (685,929)

Distillate Correction (133,980) (144,699) (156,275)HFO Process & Heating (26,796) (28,940) (31,255)Operating Engineer (164,324) (169,254) (174,332)Chemical Consumption 0 0 0Scrubber Loads (66,990) (72,349) (78,137)M&R Equip & Labor (230,469) (238,074) (245,931)

Savings ‐ Fuel Differential 3,349,508 3,617,469 3,906,867NPV & IRR

Cash Flow (8,868,468) 2,726,949 2,964,153 3,220,937

Discount Factor 1.0000 0.9091 0.8264 0.7513Present Value (8,868,468) 2,479,044 2,449,713 2,419,938Net Present Value (at Year 0) (1,519,772)

Internal Rate of Return 0.24%

Exhaust Gas Cleaning SystemsOperators Guide

Life Cycle Cost ‐ Op Years Details

Sheet 46 of 77

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Opeating Years Minimum

Capital Cost ‐ Total

EquipmentAcquisition

Expenses ‐ Total

Distillate Correction

HFO Process & Heating

Operating EngineerChemical Consumption

Scrubber LoadsM&R Equip & Labor

Savings ‐ Fuel DifferentialNPV & IRR

Cash FlowDiscount FactorPresent ValueNet Present Value (at Year 0)

Internal Rate of Return

Year

6 7 8 9 10

Exhaust Gas Cleaning SystemsOperators Guide

Life Cycle Cost ‐ Op Years Details

Sheet 47 of 77

Fil
Opeating Years 10 Year

01234

Capital Cost ‐ Total (8,868,468)

Equipment (5,577,653)Acquisition (3,290,815)

Expenses ‐ Total (622,559) (653,316) (685,929) (720,528) 

Distillate Correction (133,980) (144,699) (156,275) (168,777) HFO Process & Heating (26,796) (28,940) (31,255) (33,755) Operating Engineer (164,324) (169,254) (174,332) (179,562) Chemical Consumption 0000

Scrubber Loads (66,990) (72,349) (78,137) (84,388) 

M&R Equip & Labor (230,469) (238,074) (245,931) (254,046) 

Savings ‐ Fuel Differential 3,349,508 3,617,469 3,906,867 4,219,416 NPV & IRR

Cash Flow (8,868,468) 2,726,949 2,964,153 3,220,937 3,498,888 

Discount Factor 1.0000 0.9091 0.8264 0.7513 0.6830 Present Value (8,868,468) 2,479,044 2,449,713 2,419,938 2,389,787 Net Present Value 14,562,028

Internal Rate of Return 36.17%

Exhaust Gas Cleaning SystemsOperators Guide

Life Cycle Cost ‐ Op Years Details

Sheet 48 of 77

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Opeating Years 10

Capital Cost ‐ Total

EquipmentAcquisition

Expenses ‐ Total

Distillate Correction

HFO Process & Heating

Operating EngineerChemical Consumption

Scrubber LoadsM&R Equip & Labor

Savings ‐ Fuel DifferentialNPV & IRR

Cash FlowDiscount FactorPresent ValueNet Present Value

Internal Rate of Return

Year

6 7 8 9 10

(796,251) (837,685) (881,727) (928,564) (978,397)

(196,861) (212,610) (229,619) (247,988) (267,827)

(39,372) (42,522) (45,924) (49,598) (53,565)

(190,497) (196,212) (202,098) (208,161) (214,406)

00000

(98,431) (106,305) (114,809) (123,994) (133,914)

(271,090) (280,036) (289,277) (298,823) (308,684)

4,921,527 5,315,249 5,740,469 6,199,706 6,695,683

4,125,276 4,477,564 4,858,742 5,271,142 5,717,286

0.5645 0.5132 0.4665 0.4241 0.3855

2,328,611 2,297,698 2,266,639 2,235,479 2,204,261

Exhaust Gas Cleaning SystemsOperators Guide

Life Cycle Cost ‐ Op Years Details

Sheet 49 of 77

Fil
Opeating Years 15 Year

01234

Capital Cost ‐ Total (8,868,468)

Equipment (5,577,653)Acquisition (3,290,815)

Expenses ‐ Total (622,559) (653,316) (685,929) (720,528) 

Distillate Correction (133,980) (144,699) (156,275) (168,777) HFO Process & Heating (26,796) (28,940) (31,255) (33,755) Operating Engineer (164,324) (169,254) (174,332) (179,562) Chemical Consumption 0000

Scrubber Loads (66,990) (72,349) (78,137) (84,388) 

M&R Equip & Labor (230,469) (238,074) (245,931) (254,046) 

Savings ‐ Fuel Differential 3,349,508 3,617,469 3,906,867 4,219,416 NPV & IRR

Cash Flow (8,868,468) 2,726,949 2,964,153 3,220,937 3,498,888 

Discount Factor 1.0000 0.9091 0.8264 0.7513 0.6830 Present Value (8,868,468) 2,479,044 2,449,713 2,419,938 2,389,787 Net Present Value 14,562,028

Internal Rate of Return 36.17%

Exhaust Gas Cleaning SystemsOperators Guide

Life Cycle Cost ‐ Op Years Details

Sheet 50 of 77

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Opeating Years 15

Capital Cost ‐ Total

EquipmentAcquisition

Expenses ‐ Total

Distillate Correction

HFO Process & Heating

Operating EngineerChemical Consumption

Scrubber LoadsM&R Equip & Labor

Savings ‐ Fuel DifferentialNPV & IRR

Cash FlowDiscount FactorPresent ValueNet Present Value

Internal Rate of Return

Year

6 7 8 9 10

(796,251) (837,685) (881,727) (928,564) (978,397)

(196,861) (212,610) (229,619) (247,988) (267,827)

(39,372) (42,522) (45,924) (49,598) (53,565)

(190,497) (196,212) (202,098) (208,161) (214,406)

00000

(98,431) (106,305) (114,809) (123,994) (133,914)

(271,090) (280,036) (289,277) (298,823) (308,684)

4,921,527 5,315,249 5,740,469 6,199,706 6,695,683

4,125,276 4,477,564 4,858,742 5,271,142 5,717,286

0.5645 0.5132 0.4665 0.4241 0.3855

2,328,611 2,297,698 2,266,639 2,235,479 2,204,261

Exhaust Gas Cleaning SystemsOperators Guide

Life Cycle Cost ‐ Op Years Details

Sheet 51 of 77

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Opeating Years 15

11 12 13 14 15

Capital Cost ‐ Total

EquipmentAcquisition

Expenses ‐ Total (1,031,440) (1,087,926) (1,148,106) (1,212,248) (1,280,641)

Distillate Correction (289,253) (312,394) (337,385) (364,376) (393,526)HFO Process & Heating (57,851) (62,479) (67,477) (72,875) (78,705)Operating Engineer (220,838) (227,463) (234,287) (241,316) (248,555)

Chemical Consumption 0 0000

Scrubber Loads (144,627) (156,197) (168,693) (182,188) (196,763)

M&R Equip & Labor (318,871) (329,394) (340,264) (351,492) (363,092)

Savings ‐ Fuel Differential 7,231,337 7,809,844 8,434,632 9,109,402 9,838,155

NPV & IRR

Cash Flow 6,199,897 6,721,918 7,286,526 7,897,155 8,557,513Discount Factor 0.3505 0.3186 0.2897 0.2633 0.2394Present Value 2,173,026 2,141,810 2,110,647 2,079,568 2,048,601Net Present Value

Internal Rate of Return

Exhaust Gas Cleaning SystemsOperators Guide

Life Cycle Cost ‐ Op Years Details

Sheet 52 of 77

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Opeating Years 15

Capital Cost ‐ Total

EquipmentAcquisition

Expenses ‐ Total

Distillate Correction

HFO Process & Heating

Operating EngineerChemical Consumption

Scrubber LoadsM&R Equip & Labor

Savings ‐ Fuel DifferentialNPV & IRR

Cash FlowDiscount FactorPresent ValueNet Present Value

Internal Rate of Return

Page Not Used

Exhaust Gas Cleaning SystemsOperators Guide

Life Cycle Cost ‐ Op Years Details

Sheet 53 of 77

Fil
Opeating Years 20 Year

01234

Capital Cost ‐ Total (8,868,468)

Equipment (5,577,653)Acquisition (3,290,815)

Expenses ‐ Total (622,559) (653,316) (685,929) (720,528) 

Distillate Correction (133,980) (144,699) (156,275) (168,777) HFO Process & Heating (26,796) (28,940) (31,255) (33,755) Operating Engineer (164,324) (169,254) (174,332) (179,562) Chemical Consumption 0000

Scrubber Loads (66,990) (72,349) (78,137) (84,388) 

M&R Equip & Labor (230,469) (238,074) (245,931) (254,046) 

Savings ‐ Fuel Differential 3,349,508 3,617,469 3,906,867 4,219,416 NPV & IRR

Cash Flow (8,868,468) 2,726,949 2,964,153 3,220,937 3,498,888 

Discount Factor 1.0000 0.9091 0.8264 0.7513 0.6830 Present Value (8,868,468) 2,479,044 2,449,713 2,419,938 2,389,787 Net Present Value 14,562,028

Internal Rate of Return 36.17%

Exhaust Gas Cleaning SystemsOperators Guide

Life Cycle Cost ‐ Op Years Details

Sheet 54 of 77

Fil
Opeating Years 20

Capital Cost ‐ Total

EquipmentAcquisition

Expenses ‐ Total

Distillate Correction

HFO Process & Heating

Operating EngineerChemical Consumption

Scrubber LoadsM&R Equip & Labor

Savings ‐ Fuel DifferentialNPV & IRR

Cash FlowDiscount FactorPresent ValueNet Present Value

Internal Rate of Return

Year

6 7 8 9 10

(796,251) (837,685) (881,727) (928,564) (978,397)

(196,861) (212,610) (229,619) (247,988) (267,827)

(39,372) (42,522) (45,924) (49,598) (53,565)

(190,497) (196,212) (202,098) (208,161) (214,406)

00000

(98,431) (106,305) (114,809) (123,994) (133,914)

(271,090) (280,036) (289,277) (298,823) (308,684)

4,921,527 5,315,249 5,740,469 6,199,706 6,695,683

4,125,276 4,477,564 4,858,742 5,271,142 5,717,286

0.5645 0.5132 0.4665 0.4241 0.3855

2,328,611 2,297,698 2,266,639 2,235,479 2,204,261

Exhaust Gas Cleaning SystemsOperators Guide

Life Cycle Cost ‐ Op Years Details

Sheet 55 of 77

Fil
Opeating Years 20

11 12 13 14 15 

Capital Cost ‐ Total

EquipmentAcquisition

Expenses ‐ Total (1,031,440) (1,087,926) (1,148,106) (1,212,248) (1,280,641) 

Distillate Correction (289,253) (312,394) (337,385) (364,376) (393,526) HFO Process & Heating (57,851) (62,479) (67,477) (72,875) (78,705) Operating Engineer (220,838) (227,463) (234,287) (241,316) (248,555) 

Chemical Consumption 0 0000

Scrubber Loads (144,627) (156,197) (168,693) (182,188) (196,763) 

M&R Equip & Labor (318,871) (329,394) (340,264) (351,492) (363,092) 

Savings ‐ Fuel Differential 7,231,337 7,809,844 8,434,632 9,109,402 9,838,155 

NPV & IRR

Cash Flow 6,199,897 6,721,918 7,286,526 7,897,155 8,557,513 Discount Factor 0.3505 0.3186 0.2897 0.2633 0.2394 Present Value 2,173,026 2,141,810 2,110,647 2,079,568 2,048,601 Net Present Value

Internal Rate of Return

Exhaust Gas Cleaning SystemsOperators Guide

Life Cycle Cost ‐ Op Years Details

Sheet 56 of 77

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Opeating Years 20

Capital Cost ‐ Total

EquipmentAcquisition

Expenses ‐ Total

Distillate Correction

HFO Process & Heating

Operating EngineerChemical Consumption

Scrubber LoadsM&R Equip & Labor

Savings ‐ Fuel DifferentialNPV & IRR

Cash FlowDiscount FactorPresent ValueNet Present Value

Internal Rate of Return

17 18 19 20

(1,431,459) (1,514,580) (1,603,356) (1,698,205)

(459,009) (495,730) (535,388) (578,219)

(91,802) (99,146) (107,078) (115,644)

(263,692) (271,603) (279,751) (288,144)

0000

(229,504) (247,865) (267,694) (289,110)(387,451) (400,237) (413,445) (427,089)

11,475,224 12,393,241 13,384,701 14,455,477

10,043,765 10,878,661 11,781,345 12,757,272

0.1978 0.1799 0.1635 0.1486

1,987,105 1,956,623 1,926,344 1,896,287

Exhaust Gas Cleaning SystemsOperators Guide

Life Cycle Cost ‐ Op Years Details

Sheet 57 of 77

Fil
Ship/Route Pair

Containership

Alaska to Puget

Sound

Containership

Alaska to Puget

Sound

Containership

Alaska to Puget

Sound

Containe

Alaska to 

Soun

Scrubber Type Open Loop Open Loop Open Loop Open Lo

Sensitivity Analysis Expenses Low Predicted High V. Hig

VARIABLES ‐ CONTROLLEDInvestment Terms

Life Cycle (# of Years) 10 10 10 10

Analysis Date (Today) (Year) 2011 2011 2011 2011

Scrubber Installation Date (Year) 2014 2014 2014 2014Discount Rate (%) 10.0% 10.0% 10.0% 10.0%

Capital Expense for Scrubber

Equipment (Today) (USD/One Time) $3,795,000 $5,060,000 $5,566,000 $6,325,

Engineering/Design (% Equip Cost) 5.3% 7.0% 8.8% 11.0%

Training/Documents (% Equip Cost) 1.5% 2.0% 2.5% 2.0%Install/Commission (% Equip Cost) 37.5% 50.0% 62.5% 65.0%

Operating Expense ‐ Annual

ECA Fuel Consumption (MT/Annual) 9,636 9,636 9,636 9,636

Chemical Consumption (% of Fuel Cost) 0.0% 0.0% 0.0% 0.0%

Scrubber Parasitic Loads (% of Fuel Cost) 2.0% 2.0% 2.0% 2.0%Distillate Calorie Correction (% of Fuel Cost) 4.0% 4.0% 4.0% 4.0%HFO Process and Heating (% of Fuel Cost) 0.8% 0.8% 0.8% 0.8%Operating Engineer (Today) (USD/Annual) $219,000 $292,000 $365,000 $400,0

Operating Engineer (% of Position) 37.5% 50.0% 62.5% 100.0

M&R Equipment (% Equip Cost/Annual) 3.0% 4.0% 5.0% 8.0%

Variables ‐ Uncertain

Fuel Differential (Today) (USD/MT) $255.50 $255.50 $255.50 $255.5

Fuel/Chemical Escalation Rate (% ‐ Annual for Op Period) 8.0% 8.0% 8.0% 8.0%

Personnel Inflation Rate (% ‐ Annual for Op Period) 3.0% 3.0% 3.0% 3.0%Equipment Inflation Rate (% ‐ Annual for Op Period) 3.3% 3.3% 3.3% 3.3%

Exhaust Gas Cleaning SystemsOperators Guide

Life Cycle Cost ‐ Expenses Summary

Sheet 58 of 77

Fil
Analysis Results ‐ Overview (Nearest $1,000)

Capital Cost (USD ‐ Year Zero Dollars) (6,034,000) (8,868,000) (10,660,000) (12,410,

Expenses ‐ Year One (USD ‐ Year One Dollars) (450,000) (623,000) (801,000) (1,254,0

Fuel Savings ‐ Year One (USD ‐ Year One Dollars) 3,350,000 3,350,000 3,350,000 3,350,0

Net Present Value (USD ‐ Present Dollars) 18,593,000 14,562,000 11,532,000 6,645,0

Internal Rate of Return (%) 55% 36% 28% 20%

Exhaust Gas Cleaning SystemsOperators Guide

Life Cycle Cost ‐ Expenses Summary

Sheet 59 of 77

Fil
Expenses Low Year

01234

Capital Cost ‐ Total (6,034,323)

Equipment (4,183,240)Acquisition (1,851,084)

Expenses ‐ Total (449,838) (475,110) (502,064) (530,825) 

Distillate Correction (133,980) (144,699) (156,275) (168,777) HFO Process & Heating (26,796) (28,940) (31,255) (33,755) Operating Engineer (92,432) (95,205) (98,062) (101,003) Chemical Consumption 0000

Scrubber Loads (66,990) (72,349) (78,137) (84,388) 

M&R Equip & Labor (129,639) (133,917) (138,336) (142,901) 

Savings ‐ Fuel Differential 3,349,508 3,617,469 3,906,867 4,219,416 NPV & IRR

Cash Flow (6,034,323) 2,899,671 3,142,359 3,404,802 3,688,591 

Discount Factor 1.0000 0.9091 0.8264 0.7513 0.6830 Present Value (6,034,323) 2,636,064 2,596,991 2,558,078 2,519,357 Net Present Value (at Year 0) 18,593,214

Internal Rate of Return 55.06%

Exhaust Gas Cleaning SystemsOperators Guide

Life Cycle Cost ‐ Expenses Details

Sheet 60 of 77

Fil
Expenses Low

Capital Cost ‐ Total

EquipmentAcquisition

Expenses ‐ Total

Distillate Correction

HFO Process & Heating

Operating EngineerChemical Consumption

Scrubber LoadsM&R Equip & Labor

Savings ‐ Fuel DifferentialNPV & IRR

Cash FlowDiscount FactorPresent ValueNet Present Value (at Year 0)

Internal Rate of Return

Year

6 7 8 9 10

(594,306) (629,326) (666,750) (706,759) (749,545)

(196,861) (212,610) (229,619) (247,988) (267,827)

(39,372) (42,522) (45,924) (49,598) (53,565)

(107,154) (110,369) (113,680) (117,091) (120,603)

00000

(98,431) (106,305) (114,809) (123,994) (133,914)

(152,488) (157,520) (162,718) (168,088) (173,635)

4,921,527 5,315,249 5,740,469 6,199,706 6,695,683

4,327,220 4,685,923 5,073,718 5,492,948 5,946,138

0.5645 0.5132 0.4665 0.4241 0.3855

2,442,603 2,404,619 2,366,927 2,329,546 2,292,494

Exhaust Gas Cleaning SystemsOperators Guide

Life Cycle Cost ‐ Expenses Details

Sheet 61 of 77

Fil
Expenses Predicted Year

01234

Capital Cost ‐ Total (8,868,468)

Equipment (5,577,653)Acquisition (3,290,815)

Expenses ‐ Total (622,559) (653,316) (685,929) (720,528) 

Distillate Correction (133,980) (144,699) (156,275) (168,777) HFO Process & Heating (26,796) (28,940) (31,255) (33,755) Operating Engineer (164,324) (169,254) (174,332) (179,562) Chemical Consumption 0000

Scrubber Loads (66,990) (72,349) (78,137) (84,388) 

M&R Equip & Labor (230,469) (238,074) (245,931) (254,046) 

Savings ‐ Fuel Differential 3,349,508 3,617,469 3,906,867 4,219,416 NPV & IRR

Cash Flow (8,868,468) 2,726,949 2,964,153 3,220,937 3,498,888 

Discount Factor 1.0000 0.9091 0.8264 0.7513 0.6830 Present Value (8,868,468) 2,479,044 2,449,713 2,419,938 2,389,787 Net Present Value 14,562,028

Internal Rate of Return 36.17%

Exhaust Gas Cleaning SystemsOperators Guide

Life Cycle Cost ‐ Expenses Details

Sheet 62 of 77

Fil
Expenses Predicted

Capital Cost ‐ Total

EquipmentAcquisition

Expenses ‐ Total

Distillate Correction

HFO Process & Heating

Operating EngineerChemical Consumption

Scrubber LoadsM&R Equip & Labor

Savings ‐ Fuel DifferentialNPV & IRR

Cash FlowDiscount FactorPresent ValueNet Present Value

Internal Rate of Return

Year

6 7 8 9 10

(796,251) (837,685) (881,727) (928,564) (978,397)

(196,861) (212,610) (229,619) (247,988) (267,827)

(39,372) (42,522) (45,924) (49,598) (53,565)

(190,497) (196,212) (202,098) (208,161) (214,406)

00000

(98,431) (106,305) (114,809) (123,994) (133,914)

(271,090) (280,036) (289,277) (298,823) (308,684)

4,921,527 5,315,249 5,740,469 6,199,706 6,695,683

4,125,276 4,477,564 4,858,742 5,271,142 5,717,286

0.5645 0.5132 0.4665 0.4241 0.3855

2,328,611 2,297,698 2,266,639 2,235,479 2,204,261

Exhaust Gas Cleaning SystemsOperators Guide

Life Cycle Cost ‐ Expenses Details

Sheet 63 of 77

Fil
Expenses High Year

01234

Capital Cost ‐ Total (10,660,289)

Equipment (6,135,418)Acquisition (4,524,871)

Expenses ‐ Total (801,418) (837,799) (876,215) (916,799) 

Distillate Correction (133,980) (144,699) (156,275) (168,777) HFO Process & Heating (26,796) (28,940) (31,255) (33,755) Operating Engineer (256,757) (264,459) (272,393) (280,565) Chemical Consumption 0000

Scrubber Loads (66,990) (72,349) (78,137) (84,388) 

M&R Equip & Labor (316,894) (327,352) (338,154) (349,314) 

Savings ‐ Fuel Differential 3,349,508 3,617,469 3,906,867 4,219,416 NPV & IRR

Cash Flow (10,660,289) 2,548,091 2,779,670 3,030,652 3,302,617 

Discount Factor 1.0000 0.9091 0.8264 0.7513 0.6830 Present Value (10,660,289) 2,316,446 2,297,248 2,276,974 2,255,732 

Net Present Value 11,532,079

Internal Rate of Return 28.15%

Exhaust Gas Cleaning SystemsOperators Guide

Life Cycle Cost ‐ Expenses Details

Sheet 64 of 77

Fil
Expenses High

Capital Cost ‐ Total

EquipmentAcquisition

Expenses ‐ Total

Distillate Correction

HFO Process & Heating

Operating EngineerChemical Consumption

Scrubber LoadsM&R Equip & Labor

Savings ‐ Fuel DifferentialNPV & IRR

Cash FlowDiscount FactorPresent ValueNet Present Value

Internal Rate of Return

Year

6 7 8 9 10

(1,005,064) (1,053,067) (1,103,886) (1,157,714) (1,214,757)

(196,861) (212,610) (229,619) (247,988) (267,827)

(39,372) (42,522) (45,924) (49,598) (53,565)

(297,651) (306,581) (315,778) (325,252) (335,009)

00000

(98,431) (106,305) (114,809) (123,994) (133,914)

(372,749) (385,049) (397,756) (410,882) (424,441)

4,921,527 5,315,249 5,740,469 6,199,706 6,695,683

3,916,463 4,262,182 4,636,583 5,041,993 5,480,926

0.5645 0.5132 0.4665 0.4241 0.3855

2,210,741 2,187,173 2,163,000 2,138,297 2,113,134

Exhaust Gas Cleaning SystemsOperators Guide

Life Cycle Cost ‐ Expenses Details

Sheet 65 of 77

Fil
Expenses V. High Year

01234

Capital Cost ‐ Total (12,410,278)

Equipment (6,972,066)Acquisition (5,438,212)

Expenses ‐ Total (1,254,142) (1,304,883) (1,358,114) (1,413,985) 

Distillate Correction (133,980) (144,699) (156,275) (168,777) HFO Process & Heating (26,796) (28,940) (31,255) (33,755) Operating Engineer (450,204) (463,710) (477,621) (491,950) Chemical Consumption 0000

Scrubber Loads (66,990) (72,349) (78,137) (84,388) 

M&R Equip & Labor (576,172) (595,185) (614,826) (635,116) 

Savings ‐ Fuel Differential 3,349,508 3,617,469 3,906,867 4,219,416 NPV & IRR

Cash Flow (12,410,278) 2,095,367 2,312,586 2,548,752 2,805,430 

Discount Factor 1.0000 0.9091 0.8264 0.7513 0.6830 Present Value (12,410,278) 1,904,879 1,911,228 1,914,915 1,916,147 

Net Present Value 6,644,910

Internal Rate of Return 19.56%

Exhaust Gas Cleaning SystemsOperators Guide

Life Cycle Cost ‐ Expenses Details

Sheet 66 of 77

Fil
Expenses V. High

Capital Cost ‐ Total

EquipmentAcquisition

Expenses ‐ Total

Distillate Correction

HFO Process & Heating

Operating EngineerChemical Consumption

Scrubber LoadsM&R Equip & Labor

Savings ‐ Fuel DifferentialNPV & IRR

Cash FlowDiscount FactorPresent ValueNet Present Value

Internal Rate of Return

Year

6 7 8 9 10

(1,534,298) (1,599,093) (1,667,238) (1,738,942) (1,814,431)

(196,861) (212,610) (229,619) (247,988) (267,827)

(39,372) (42,522) (45,924) (49,598) (53,565)

(521,909) (537,567) (553,694) (570,304) (587,413)

00000

(98,431) (106,305) (114,809) (123,994) (133,914)

(677,725) (700,090) (723,193) (747,058) (771,711)

4,921,527 5,315,249 5,740,469 6,199,706 6,695,683

3,387,229 3,716,156 4,073,231 4,460,764 4,881,252

0.5645 0.5132 0.4665 0.4241 0.3855

1,912,002 1,906,975 1,900,192 1,891,799 1,881,934

Exhaust Gas Cleaning SystemsOperators Guide

Life Cycle Cost ‐ Expenses Details

Sheet 67 of 77

Fil
Ship/Route Pair

Containership

Alaska to Puget

Sound

Containership

Alaska to Puget

Sound

Containership

Alaska to Puget

Sound

Containe

Alaska to 

Soun

Scrubber Type Open Loop Open Loop Open Loop Open Lo

Sensitivity Analysis Expenses Low Predicted High V. Hig

Combination of Variables Fuel/CPI‐PPI 11/5 8/3 5/2 2/1VARIABLES ‐ CONTROLLEDInvestment Terms

Life Cycle (# of Years) 10 10 10 10

Analysis Date (Today) (Year) 2011 2011 2011 2011

Scrubber Installation Date (Year) 2014 2014 2014 2014Discount Rate (%) 10.0% 10.0% 10.0% 10.0%

Capital Expense for Scrubber

Equipment (Today) (USD/One Time) $3,795,000 $5,060,000 $5,566,000 $6,325,

Engineering/Design (% Equip Cost) 5.0% 7.0% 9.0% 11.0%

Training/Documents (% Equip Cost) 2.0% 2.0% 2.0% 2.0%Install/Commission (% Equip Cost) 40.0% 50.0% 60.0% 65.0%

Operating Expense ‐ Annual

ECA Fuel Consumption (MT/Annual) 9,636 9,636 9,636 9,636

Chemical Consumption (% of Fuel Cost) 0.0% 0.0% 0.0% 0.0%

Scrubber Parasitic Loads (% of Fuel Cost) 2.0% 2.0% 2.0% 2.0%Distillate Calorie Correction (% of Fuel Cost) 4.0% 4.0% 4.0% 4.0%HFO Process and Heating (% of Fuel Cost) 0.8% 0.8% 0.8% 0.8%Operating Engineer (Today) (USD/Annual) $200,000 $292,000 $350,000 $400,0

Operating Engineer (% of Position) 25.0% 50.0% 75.0% 100.0

M&R Equipment (% Equip Cost/Annual) 2.0% 4.0% 6.0% 8.0%

Variables ‐ Uncertain

Fuel Differential (Today) (USD/MT) $255.50 $255.50 $255.50 $255.5

Fuel/Chemical Escalation Rate (% ‐ Annual for Op Period) 11.0% 8.0% 5.0% 2.0%

Personnel Inflation Rate (% ‐ Annual for Op Period) 5.0% 3.0% 2.0% 1.0%

Equipment Inflation Rate (% ‐ Annual for Op Period) 5.0% 3.3% 2.0% 1.0%

Exhaust Gas Cleaning SystemsOperators Guide

Life Cycle Cost ‐ Combination Summary

Sheet 68 of 77

Fil
Analysis Results ‐ Overview (Nearest $1,000)

Capital Cost (USD ‐ Year Zero Dollars) (6,458,000) (8,868,000) (10,100,000) (12,405,

Expenses ‐ Year One (USD ‐ Year One Dollars) (407,000) (623,000) (849,000) (1,124,0

Fuel Savings ‐ Year One (USD ‐ Year One Dollars) 3,737,000 3,350,000 2,993,000 2,665,0

Net Present Value (USD ‐ Present Dollars) 25,397,000 14,562,000 6,372,000 (1,964,0

Internal Rate of Return (%) 62% 36% 22% 6%

Exhaust Gas Cleaning SystemsOperators Guide

Life Cycle Cost ‐ Combination Summary

Sheet 69 of 77

Fil
Expenses Low Year

Fuel/CPI‐PPI 11/5 01234

Capital Cost ‐ Total (6,457,985)

Equipment (4,393,187)Acquisition (2,064,798)

Expenses ‐ Total (407,180) (442,788) (481,854) (524,735) 

Distillate Correction (149,499) (165,944) (184,198) (204,459) HFO Process & Heating (29,900) (33,189) (36,840) (40,892) Operating Engineer (60,775) (63,814) (67,005) (70,355) Chemical Consumption 0000

Scrubber Loads (74,749) (82,972) (92,099) (102,230) 

M&R Equip & Labor (92,257) (96,870) (101,713) (106,799) 

Savings ‐ Fuel Differential 3,737,472 4,148,594 4,604,939 5,111,483 

NPV & IRR

Cash Flow (6,457,985) 3,330,292 3,705,806 4,123,085 4,586,748 

Discount Factor 1.0000 0.9091 0.8264 0.7513 0.6830 Present Value (6,457,985) 3,027,538 3,062,649 3,097,735 3,132,811 Net Present Value (at Year 0) 25,397,427

Internal Rate of Return 61.59%

Exhaust Gas Cleaning SystemsOperators Guide

Life Cycle Cost ‐ Combination Details

Sheet 70 of 77

Fil
Expenses Low

Fuel/CPI‐PPI 11/5Capital Cost ‐ Total

EquipmentAcquisition

Expenses ‐ Total

Distillate Correction

HFO Process & Heating

Operating EngineerChemical Consumption

Scrubber LoadsM&R Equip & Labor

Savings ‐ Fuel DifferentialNPV & IRR

Cash FlowDiscount FactorPresent ValueNet Present Value (at Year 0)

Internal Rate of Return

Year

6 7 8 9 10

(623,567) (680,440) (742,984) (811,792) (887,523)

(251,914) (279,625) (310,384) (344,526) (382,424)

(50,383) (55,925) (62,077) (68,905) (76,485)(77,566) (81,445) (85,517) (89,793) (94,282)

00000

(125,957) (139,812) (155,192) (172,263) (191,212)(117,746) (123,633) (129,815) (136,305) (143,121)

6,297,858 6,990,622 7,759,591 8,613,146 9,560,592

5,674,291 6,310,182 7,016,607 7,801,353 8,673,068

0.5645 0.5132 0.4665 0.4241 0.3855

3,202,990 3,238,121 3,273,299 3,308,535 3,343,843

Exhaust Gas Cleaning SystemsOperators Guide

Life Cycle Cost ‐ Combination Details

Sheet 71 of 77

Fil
Expenses Predicted Year

Fuel/CPI‐PPI 8/3 01234

Capital Cost ‐ Total (8,868,468)

Equipment (5,577,653)Acquisition (3,290,815)

Expenses ‐ Total (622,559) (653,316) (685,929) (720,528) 

Distillate Correction (133,980) (144,699) (156,275) (168,777) HFO Process & Heating (26,796) (28,940) (31,255) (33,755) Operating Engineer (164,324) (169,254) (174,332) (179,562) Chemical Consumption 0000

Scrubber Loads (66,990) (72,349) (78,137) (84,388) 

M&R Equip & Labor (230,469) (238,074) (245,931) (254,046) 

Savings ‐ Fuel Differential 3,349,508 3,617,469 3,906,867 4,219,416 NPV & IRR

Cash Flow (8,868,468) 2,726,949 2,964,153 3,220,937 3,498,888 

Discount Factor 1.0000 0.9091 0.8264 0.7513 0.6830 Present Value (8,868,468) 2,479,044 2,449,713 2,419,938 2,389,787 Net Present Value 14,562,028

Internal Rate of Return 36.17%

Exhaust Gas Cleaning SystemsOperators Guide

Life Cycle Cost ‐ Combination Details

Sheet 72 of 77

Fil
Expenses Predicted

Fuel/CPI‐PPI 8/3Capital Cost ‐ Total

EquipmentAcquisition

Expenses ‐ Total

Distillate Correction

HFO Process & Heating

Operating EngineerChemical Consumption

Scrubber LoadsM&R Equip & Labor

Savings ‐ Fuel DifferentialNPV & IRR

Cash FlowDiscount FactorPresent ValueNet Present Value

Internal Rate of Return

Year

6 7 8 9 10

(796,251) (837,685) (881,727) (928,564) (978,397)

(196,861) (212,610) (229,619) (247,988) (267,827)

(39,372) (42,522) (45,924) (49,598) (53,565)

(190,497) (196,212) (202,098) (208,161) (214,406)

00000

(98,431) (106,305) (114,809) (123,994) (133,914)

(271,090) (280,036) (289,277) (298,823) (308,684)

4,921,527 5,315,249 5,740,469 6,199,706 6,695,683

4,125,276 4,477,564 4,858,742 5,271,142 5,717,286

0.5645 0.5132 0.4665 0.4241 0.3855

2,328,611 2,297,698 2,266,639 2,235,479 2,204,261

Exhaust Gas Cleaning SystemsOperators Guide

Life Cycle Cost ‐ Combination Details

Sheet 73 of 77

Fil
Expenses High Year

Fuel/CPI‐PPI 5/2 01234

Capital Cost ‐ Total (10,100,429)

Equipment (5,906,684)Acquisition (4,193,745)

Expenses ‐ Total (849,122) (872,209) (896,063) (920,715) 

Distillate Correction (119,703) (125,688) (131,972) (138,571) HFO Process & Heating (23,941) (25,138) (26,394) (27,714) Operating Engineer (284,138) (289,821) (295,618) (301,530) Chemical Consumption 0000

Scrubber Loads (59,851) (62,844) (65,986) (69,285) 

M&R Equip & Labor (361,489) (368,719) (376,093) (383,615) 

Savings ‐ Fuel Differential 2,992,563 3,142,191 3,299,300 3,464,265 NPV & IRR

Cash Flow (10,100,429) 2,143,441 2,269,982 2,403,237 2,543,550 

Discount Factor 1.0000 0.9091 0.8264 0.7513 0.6830 Present Value (10,100,429) 1,948,583 1,876,018 1,805,588 1,737,279 

Net Present Value 6,372,232

Internal Rate of Return 21.88%

Exhaust Gas Cleaning SystemsOperators Guide

Life Cycle Cost ‐ Combination Details

Sheet 74 of 77

Fil
Expenses High

Fuel/CPI‐PPI 5/2Capital Cost ‐ Total

EquipmentAcquisition

Expenses ‐ Total

Distillate Correction

HFO Process & Heating

Operating EngineerChemical Consumption

Scrubber LoadsM&R Equip & Labor

Savings ‐ Fuel DifferentialNPV & IRR

Cash FlowDiscount FactorPresent ValueNet Present Value

Internal Rate of Return

Year

6 7 8 9 10

(972,541) (999,783) (1,027,960) (1,057,109) (1,087,271)

(152,774) (160,413) (168,433) (176,855) (185,698)

(30,555) (32,083) (33,687) (35,371) (37,140)

(313,712) (319,986) (326,386) (332,913) (339,572)

00000

(76,387) (80,206) (84,217) (88,428) (92,849)

(399,113) (407,095) (415,237) (423,542) (432,013)

3,819,352 4,010,320 4,210,836 4,421,378 4,642,447

2,846,812 3,010,537 3,182,876 3,364,269 3,555,176

0.5645 0.5132 0.4665 0.4241 0.3855

1,606,951 1,544,881 1,484,835 1,426,778 1,370,674

Exhaust Gas Cleaning SystemsOperators Guide

Life Cycle Cost ‐ Combination Details

Sheet 75 of 77

Fil
Expenses V. High Year

Fuel/CPI‐PPI 2/1 01234

Capital Cost ‐ Total (12,404,968)

Equipment (7,321,978)Acquisition (5,082,990)

Expenses ‐ Total (1,124,003) (1,137,055) (1,150,274) (1,163,662) 

Distillate Correction (106,597) (108,729) (110,904) (113,122) HFO Process & Heating (21,319) (21,746) (22,181) (22,624) Operating Engineer (416,242) (420,404) (424,608) (428,854) Chemical Consumption 0000

Scrubber Loads (53,299) (54,365) (55,452) (56,561) 

M&R Equip & Labor (526,546) (531,811) (537,129) (542,500) 

Savings ‐ Fuel Differential 2,664,936 2,718,234 2,772,599 2,828,051 NPV & IRR

Cash Flow (12,404,968) 1,540,933 1,581,179 1,622,325 1,664,389 

Discount Factor 1.0000 0.9091 0.8264 0.7513 0.6830 Present Value (12,404,968) 1,400,848 1,306,760 1,218,877 1,136,800 

Net Present Value (1,963,698)

Internal Rate of Return 6.32%

Exhaust Gas Cleaning SystemsOperators Guide

Life Cycle Cost ‐ Combination Details

Sheet 76 of 77

Fil
Expenses V. High

Fuel/CPI‐PPI 2/1Capital Cost ‐ Total

EquipmentAcquisition

Expenses ‐ Total

Distillate Correction

HFO Process & Heating

Operating EngineerChemical Consumption

Scrubber LoadsM&R Equip & Labor

Savings ‐ Fuel DifferentialNPV & IRR

Cash FlowDiscount FactorPresent ValueNet Present Value

Internal Rate of Return

Year

6 7 8 9 10

(1,190,956) (1,204,866) (1,218,955) (1,233,226) (1,247,682)

(117,692) (120,046) (122,447) (124,896) (127,394)

(23,538) (24,009) (24,489) (24,979) (25,479)

(437,474) (441,849) (446,267) (450,730) (455,237)

00000

(58,846) (60,023) (61,223) (62,448) (63,697)

(553,405) (558,939) (564,528) (570,173) (575,875)

2,942,304 3,001,150 3,061,173 3,122,397 3,184,845

1,751,349 1,796,285 1,842,218 1,889,170 1,937,163

0.5645 0.5132 0.4665 0.4241 0.3855

988,591 921,778 859,408 801,193 746,860

Exhaust Gas Cleaning SystemsOperators Guide

Life Cycle Cost ‐ Combination Details

Sheet 77 of 77

Fil