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    MARPOL 73/78 Annex VI

    Regulations for the Prevention ofAir Pollution from Ships

    Guidance Notes

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    CONTENTS

    Section Topic

    1 Introduction

    2 General

    3 MARPOL 73/78 Annex VI General Survey & Certification Requirements

    4 MARPOL 73/78 Annex VI Survey - General Requirements

    5 Reporting and Certification

    6 Requirements for Control of Emissions from Ships

    6.1 Regulation 12 - Ozone Depleting Substances (ODS)

    6.2 Regulation 13 - Nitrogen Oxides (NOx)6.3 Regulation 14 - Sulphur Oxides (SOx)

    6.4 Regulation 15 - Volatile Organic Compounds (VOC)

    6.5 Regulation 16 - Shipboard Incineration

    6.6 Regulation 17 - Reception Facilities

    6.7 Regulation 18 - Fuel Oil Quality

    6.8 Regulation 19 - Requirements for Platforms and Drilling Rigs

    Appendix I Regulation 2 - Ozone -Depleting Substances Definitions (Reg 12)

    Appendix II Test Cycles & Weighting Factors (Reg 13)

    Appendix III Guidance on Engine On-Board NOx Verification Surveys (Reg 13)

    Appendix IV Criteria & Procedures for Designation of SOx Emission Control Areas (Reg 14)

    Appendix V Type Approval & Operating Limits for Shipboard Incinerators (Reg 16)

    Appendix VI Information to be Included in the Bunker Delivery Note {Reg 18.(3)}

    Appendix VII Frequently Asked Question on Annex VI

    Appendix VIII Annex VI Survey Requirements Map

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    SECTION 1

    1. INTRODUCTION

    1.1. These Guidance Notes have been prepared for the use of Ship Owners/Managersand Lloyds Register (LR) Group Surveyors. They provide guidance on therequirements of MARPOL 73/78, Annex VI, (hereafter referred to as MARPOLAnnex VI).

    1.1.1. The document is divided into sections covering the general requirements for theapplication, survey, reporting and certification of equipment covered in MARPOLAnnex VI. Section 6 deals with each regulation and its' survey requirements. Thetext of each relevant Regulation of MARPOL Annex VI,"Chapter III - Requirementsfor Control of Emissions from Ships" is provided inItalics for ease of reference.

    1.2. MARPOL Annex VI will enter into force on 19 May 2005, although manyShipOwners have been requesting verification surveys and issue of International AirPollution (IAPP) Certificates of Compliance for some time in preparation for itsimplementation.

    1.3. MARPOL Annex VI covers six sources of air pollution from ships:

    1.3.1. Emissions of Ozone Depleting Substances

    1.3.2. Nitrogen Oxide Emissions from Diesel Engines..

    1.3.3. Sulphur Oxide Emissions.

    1.3.4. Emissions of Volatile Organic Compounds.

    1.3.5. The Incineration of Shipboard Wastes.

    1.3.6. Fuel Oil Quality

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    SECTION 2

    2. GENERAL

    2.1. After many years of debate and development, the International MaritimeOrganisation (IMO) adopted Annex VI to the MARPOL Convention in September

    1997. This new Annex is entitled Regulations for the Prevention of Air Pollution fromShips." At the same time the IMO adopted the Technical Code on Control of Emissionsof Nitrogen Oxides from Marine Diesel Engines, usually referred to as the NOxTechnical Code or simply the Code.

    2.2. MARPOL Annex VI and the NOx Technical Code (the Code) will come into force on19 May 2005.

    2.3. MARPOL Annex VI applies to all ships2, and to fixed and floating drilling rigs andother platforms. Ships of 400 gross tonnage engaged in international voyages,constructed3 on or after 19 May 2005, are required to be surveyed and issued with anIAPP Certificate on delivery of the ship. For ships of 400 gross tonnage engaged ininternational voyages, constructed prior to this date, the IAPP Certificate must beissued at the first scheduled dry docking after 19 May 2005, but no later than 19 May2008.

    2.4. The Code will apply to any diesel engine with a power output of 130 kW installedon a ship whose keel was laid on or after 1 January 2000, or any diesel engine with apower output of 130 kW which has undergone a major conversion on or after 1January 2000, except those intended solely for emergency use.

    2.5. See Appendix X for the application of MARPOL Annex VI to existing ships.

    2.6. The IMO has adopted a circular (MEPC/Circ.344), which states:

    1 Each engine which will become, retrospectively5, subject to the provisions of regulation 13of Annex VI of MARPOL 73/78 upon its entry into force, should be certified in accordancewith the requirements of the NOx Technical Code.

    2 Pending entry into force of Annex VI and upon satisfactory compliance with the Coderequirements, a "Statement of Compliance" with the NOx Technical Code should be issued bythe flag State Administration or an organisation acting on behalf of that Administration

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    SECTION 3

    3. MARPOL Annex VI - General Surveys and Certificationrequirements

    3.1. Surveys and certification will be required in a similar manner to the requirements for

    the familiar MARPOL Annex I and associated IOPP certificate.

    3.2. MARPOL Annex VI requires that every ship of 400 gross tonnes or above and everyfixed and floating drilling rig and other platforms are surveyed and issued with anInternational Air Pollution Prevention (IAPP) Certificate. The survey andcertification procedures will generally follow the same format as those for MARPOLAnnex I, IOPP certificates.

    3.2.1. Ships of 400 gross tonnes and above and every fixed and floating drilling rig andother platforms must be in possession of an IAPP Certificate. For ships under 400gross tonnes, the flag administration may establish alternative requirements, forcomplying with the provisions of Annex VI.

    3.3. An IAPP certificate will be valid for five (5) years from the date of the initial surveywhile its continued validity will be maintained by annual, intermediate and renewalsurveys. The surveys follow the IMO Harmonised System of Surveys andCertification (HSSC).

    3.4. In the period leading up to the Annex entering into force LR can on request issuecertification to demonstrate that a ship complies with the applicable regulations ofMARPOL Annex VI. LR can also test and certify that diesel engines comply withRegulation 13 of MARPOL Annex VI and the NOx Technical Code.

    3.5. Surveyors will determine any additional or specific Flag requirements prior tocommencement of a survey.

    3.6. In the case of ships of less than 400 gross tonnage, the Administration may establishappropriate measures in order to ensure that the applicable provisions of MARPOLAnnex VI are complied with.7

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    SECTION 4

    4. MARPOL ANNEX VI SURVEYS - General requirements

    4.1. A survey is conducted to confirm that the arrangements and equipment will, withproper maintenance be expected to remain in good condition and working orderuntil the next survey.

    4.1.1. MARPOL Annex VI surveys will normally be dealt with in their entirety and not aspart surveys.

    4.1.1.1. Only on those occasions where the required service facilities or necessaryreplacement equipment is not available locally would items be considered fordeferment.

    4.1.1.2. Surveys should only be held within the permitted range dates, with a certificateceasing to be valid if the periodical, intermediate or annual survey, as appropriate, isnot completed within the periods specified in the relevant regulations.

    4.1.1.3. Carrying out the appropriate survey will restore the validity of the certificate. Thethoroughness and stringency of this survey will depend on the time the survey wasallowed to lapse.

    4.1.1.4. When a survey is requested to be held after the expiry of the range dates, the Owners

    will be informed in writing that the Certificate must be considered as having beeninvalid from the expiry of the range dates until the date the survey was held.

    4.1.1.5. Renewal surveys should be completed before or by the expiry date of the certificate.

    4.1.2. Should an LR Surveyor become aware that the condition of the ship or its equipment,does not correspond with the particulars of any of the statutory certificates or thecondition of the ship is such that it is not fit to proceed to sea, without danger to the

    ship or persons on board, or presents an unreasonable threat to the marineenvironment, the Surveyor will recommend repairs to rectify the deficiencies.

    4.1.2.1. If the Surveyors recommendations are not carried out, the certificate will bewithdrawn in accordance with the requirements of MARPOL Annex VI. The Masterwill be advised in writing that the certificate is to be surrendered and that thecertificate is invalid from the date of the letter A copy of the letter will be forwarded

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    4.1.3.2. Periodical or Renewal Surveys will, in addition to the requirements of an Annual and

    Intermediate Survey, be such as to ensure that the equipment, system, fittings,arrangements and materials fully comply with the applicable requirements ofMARPOL Annex VI.

    4.1.3.3. An Annual Surveys will consist of:

    4.1.3.3.1. verification that the certificate on board is in order,

    4.1.3.3.2. an examination of the various items of equipment together with tests as considerednecessary, all to an extent which, in the Surveyors judgement, indicates adequatecondition and standard of maintenance sufficient until the next due Survey.

    4.1.3.4. An Intermediate Survey will consist of:

    4.1.3.4.1. an Annual Survey, plus

    4.1.3.4.2. a thorough examination to ensure that the equipment complies with therequirements of the Regulations and is in good working order, sufficient until thenext Survey.

    4.1.4. To assist in preparing for the survey, a draft provisional survey checklist has beendeveloped. (Refer to Appendix IX)

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    SECTION 5

    5. REPORTING AND CERTIFICATION

    5.1. The surveyor will complete the checklist (see Appendix IX) during the survey onboard the ship to ensure all relevant aspects are verified. Where necessary,

    supplementary sheets listing specific information on the systems accepted will beappended to the check list report.

    5.2. On completion of the Initial Survey, the Surveyor completes the report and issuesthe IAPP Certificate or Certificate of Compliance.

    5.2.1. A copy of the survey report and certificate will be sent to the central certificatesdatabase, from where it can be viewed and retrieved via CDLive. This ensures the

    information is available to surveyors undertaking subsequent surveys.

    5.3. A copy of the report and any certificate issued will be made available to the FlagAdministration as and when required.

    5.4. On satisfactory completion of the Intermediate/Annual Survey the IAPP certificateon board will be endorsed to show that the survey has been completed.

    5.5. On satisfactory completion of a Renewal Survey a new certificate valid for a

    maximum of five years (taking into account the requirements of the HSSC whereappropriate) will be issued with a copy of the survey report and certificate sent to thecentral database

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    SECTION 6

    6. REQUIREMENTS FOR CONTROL OF EMISSIONS FROM SHIPS

    6.1. Regulation 12 - Ozone Depleting Substances

    (1) Subject to the provisions of regulation 38 , any deliberate emissions of ozone depletingsubstances shall be prohibited. Deliberate emissions include emissions occurring in thecourse of maintaining, servicing, repairing or disposing of systems or equipment, except thatdeliberate emissions do not include minimal releases associated with the recapture orrecycling of an ozone depleting substance. Emissions arising from leaks of an ozone-depleting substance, whether or not the leaks are deliberate, may be regulated by Parties tothe Protocol of 1997.

    (2) New installations which contain ozone-depleting substances shall be prohibited on all ships,except that new installations containing hydrochlorofluorocarbons (HCFC's) are permitteduntil 1 January 2020.9

    (3) The substances referred to in this regulation, and equipment containing such substances,shall be delivered to appropriate reception facilities when removed from ships.

    6.1.1. General requirements

    6.1.1.1. The regulations prohibit the installation of systems containing, or the deliberate

    release of, CFCs, halons and other ozone-depleting substances10. When removingozone-depleting substances from a ship they are to be disposed of at appropriatereception facilities (ref. Reg. 17). This reflects existing requirements in SOLAS, theMontreal Protocol and other international agreements. In addition some flagadministrations have additional requirements.

    6.1.1.2. No fire-fighting system or other equipment such as refrigeration units is to containHalons or other ozone-depleting substances.

    6.1.1.3. For new buildings, SOLAS II-2 Regulation 5-3 prohibits the installation of systemsusing Halons.

    6.1.1.4. On existing ships, systems containing Halons can remain in service until replaced orrequired to be removed by international, national or other requirements.

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    6.1.2. Plan Appraisal for new installations

    6.1.2.1. Fire fighting systems - Fire plans will be examined for compliance with therequirements of MARPOL Annex VI when they are examined for SOLAS and Classrequirements .

    6.1.2.2. Refrigeration systems - Plans are only required to be submitted where an RMC(Refrigeration Cargo Installation) or EP (Environmental Protection) notation isrequested. Where plans are appraised for compliance with Class requirements,compliance with the requirements of MARPOL Annex VI will also to be addressed.

    6.1.2.3. For all other systems using refrigerants, e.g. domestic refrigeration systems, airconditioning systems, control air dryers, ice water machines, etc., the attendingsurveyor will verify that the media used is acceptable and in compliance with the

    requirements. These systems will be documented and attached to the initial surveyreport.

    6.1.2.4. The Design Appraisal Document (DAD) accompanying the approved plans willclearly indicate which regulations the plans have being examined for compliancewith.

    6.1.3. Initial Survey requirements

    6.1.3.1. The surveyor attending the initial SOLAS survey will confirm that the equipmentand media placed on board are in accordance with the approved fire control plansand suitable for use.

    6.1.3.2. It will be verified that no system contains CFCs, by reviewing the relevantdocumentation, certificates, etc.

    6.1.3.3. The refrigeration media requirements will be verified during the initial survey on the

    ship, the information being obtained from the manufacturer's and installer's12

    information on the systems. Systems verified on board will be documented, with acopy being attached to the initial survey report.

    6.1.3.4. The information for the surveys carried out under 6.1.3.1/2/3 above may be used forcompleting the MARPOL Annex VI survey without further examination.

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    6.2. Regulation 13 - Nitrogen Oxides (NOx)

    (1) (a) This regulation shall apply to:(i) each diesel engine with a power output of more that 130 kW which is installed on a

    ship constructed on or after 1 January 2000;13 and

    (ii) each diesel engine with a power output of more than 130 kW which undergoes amajor conversion on or after 1 January 2000.14(b) This regulation does not apply to:

    (i) emergency diesel engines, engines installed in lifeboats and any device or equipmentintended to be used solely in case of emergency;15 and

    (ii) engines installed on ships solely engaged in voyages within waters subject to thesovereignty or jurisdiction of the State the flag of which the ship is entitled to fly, provided that such engines are subject to an alternative NOx control measureestablished by the Administration.

    (c) Notwithstanding the provisions of sub-paragraph (a) of this paragraph, the Administrationmay allow exclusion from the application of this regulation to any diesel engine which isinstalled on a ship constructed, or on a ship which undergoes a major conversion 16, before thedate of entry into force of the present Protocol, provided that the ship is solely engaged invoyages to ports or offshore terminals within the State the flag of which the ship is entitled tofly.

    (2) (a) For the purpose of this regulation, "major conversion" means a modification of an enginewhere:

    (i) the engine is replaced by a new17engine built on or after 1 January 2000, or(ii) any substantial modification, as defined in the NOx Technical Code, is made to the

    engine, or

    (iii) the maximum continuous rating of the engine is increased by more than 10%18(b) The NOx emission resulting from modifications referred in the sub-paragraph (a) of this

    paragraph shall be documented in accordance with the NOx Technical Code for approval bythe Administration

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    (calculated as the total weighted emission of NO2 ) from the engine is within the followinglimits: 20

    (i) 17.0g/kWh when n is less than 130 rpm

    (ii) 45.0xn(-0.2)g/kWh when n is 130 or more but less than 2000 rpm

    (iii) 9.8 g/kWh when n is 2000 rpm or more

    Where n = rated engine speed (crankshaft revolutions per minute)

    When using fuel composed of blends from hydrocarbons derived from petroleum refining, testprocedure and measurement methods shall be in accordance with the NOx Technical Code,taking into consideration the Test Cycles and Weighting Factors outlined in appendix II tothis Annex. (NB. Refer, Appendix I of this document)

    (b) Notwithstanding the provisions of sub-paragraph (a) of this paragraph, the operation of adiesel engine is permitted when:

    (i) an exhaust gas cleaning system, approved by the Administration in accordance withthe NOx Technical Code, is applied to the engine to reduce onboard NOx emissionsat least to the limits specified in sub-paragraph (a),21 or

    (ii) any other equivalent method, approved by the Administration taking into accountrelevant guidelines to be developed by the Organisation, is applied to reduce onboardNOx emissions at least to the limit specified in sub-paragraph (a) of this paragraph.

    6.2.1 General requirements

    6.2.1.1 MARPOL Annex VI requires all diesel engines with a power output of more than 130kW to be tested and issued with an Engine International Air Pollution Prevention(EIAPP) certificate and an approved NOx Technical File. This EIAPP certificate andapproved Technical File stays with the engine and remains valid for its marine life.

    Periodic verification surveys are carried out to confirm the engine continues tooperate within the on-board NOx emission limits.

    6.2.1.2 Emergency diesel engines, lifeboat engines or any other engines installed inequipment intended solely for emergency use, do not have to comply withRegulation 13 of MARPOL Annex VI.

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    6.2.1.5 Each EIAPP certified engine is subject to an on-board verification survey afterinstallation on-board as part of the initial IAPP survey. This verification procedure,contained in the Technical File, is approved from the following available methods:

    Engine parameter method.

    Simplified measurement method.

    The direct measurement and monitoring method.

    6.2.1.6 Where an engine has no EIAPP certificate, (i.e. not pre-certified) certification will berequired prior to issue of the ship's IAPP certificate. Normally this will entail emissiontesting of the engine on-board in accordance with the full test bed requirements or, inextreme circumstances removing to a test bed.

    6.2.1.7 Note: It is the ShipOwner who nominates the method to be used to demonstratecompliance, not the flag state authority. The flag state is responsible for the acceptanceand approval of the method. The engine builder will need to supply the necessarysupporting equipment, facilities and information from the outset.

    6.2.2 Initial on-board verification Survey.

    6.2.2.1 The survey will consist of:

    6.2.2.2 Identifying which engines are required to be certified and have an approved NOxTechnical File, and that they all have NOx Emission pre-certification (EIAPP).

    6.2.2.3 A review of the engine certificates and NOx Technical Files including ensuring that theNOx Technical files have been approved.

    6.2.2.4 Verifying:

    The engine, its components, settings, and operating values remain within the limitsspecified in the approved NOx Technical File by performing the on-boardverification procedure.

    The duty stated on the EIAPP certificate equates to the installed duty, e.g. D2 =constant-speed auxiliary application, etc.

    That the cooling system is in line with that approved for the installation.

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    degree of inspection required later. (Refer to Appendix III for more specific guidance on theengine parameter method.)

    6.2.2.8 That the exhaust cleaning or other NOx reduction system, where fitted, is operational.

    6.2.3 In service surveys

    6.2.3.1 In service surveys will form part of the MARPOL Annex VI annual, intermediate andrenewal surveys. On satisfactory completion of the survey, the IAPP certificate will beendorsed to show that the annual or intermediate survey has been completed. In thecase of a renewal survey, a new certificate valid for a maximum of five years will beissued.

    6.2.3.2 The surveys will consist of:

    6.2.3.2.1 Identifying which engines are required to be certified and have an approved NOxTechnical File.

    6.2.3.2.2 A review of the engine certificates (EIAPP) and NOx Technical Files including ensuringthat the NOx Technical Files have been approved.

    6.2.3.2.3 Verifying that the Engine Parameter Book for each engine exists and is up to date andrelevant entries correctly completed.

    6.2.3.2.3.1 It should contain records of: work carried out on the engine such as modifications,setting adjustments, component replacements, details of engine manufacturers technicalnotices appertaining to the engine, details of approved modifications, etc., properlyentered, signed by either the Chief or Second Engineer or Manufacturer's Representativeas appropriate and dated.

    6.2.3.2.4 Verifying that any modification, adjustments, or replaced parts conform to the enginespecification and parameters in the NOx Technical file.

    6.2.3.3 Verification that the engine data logging systems are operational and that the datarecords are current. A review of the engine data for trends, which may indicatepossible engine problems relating to NOx emission non-compliance.

    6.2.3.4 Verifying that the engine, components and settings are as detailed in the NOx Technical

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    6.2.3.4.3 The on-board direct measurementand monitoring method of on-board verification hasbeen agreed by the IMO and adopted on 18 July 2003 under IMO ResolutionMEPC.103(49), Guidelines for On-Board NOx Verification Procedure DirectMeasurement and Monitoring Method.

    6.2.3.5 Where fitted, verifying that the direct NOx measurement system is calibrated andoperated in accordance with the manufacturer's operational recommendations and thatthe records are available.

    6.2.3.6 Where fitted verifying that the exhaust cleaning or other NOx reduction system isoperational and being operated in accordance with manufacturer's recommendations.

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    6.3 Regulation 14 - Sulphur Oxides (SOx)

    General requirements

    (1) The sulphur content of any fuel oil used on board ships shall not exceed 4.5% m/m.(2) The worldwide average sulphur content of residual fuel oil supplied for use on board ships shall be

    monitored taking into account guidelines to be developed by the Organization.

    Requirements within SOx emission control areas23

    (3) For the purpose of this regulation, SOx emission control areas shall include:(a) the Baltic Sea area as defined in regulation 10(1)(b) of Annex I; and(b) any other sea area, including port areas, designated by the Organization in accordance with

    criteria and procedures for designation of SOx emission control areas with respect to theprevention of air pollution from ships contained in appendix III to this Annex

    (4) While ships are within SOx emission control areas, at least one of the following conditions shall befulfilled:

    (a) the sulphur content of fuel oil used on board ships in a SOx emission control area does notexceed 1.5% m/m;

    (b) an exhaust gas cleaning system, approved by the Administration taking into accountguidelines to be developed by the Organization, is applied to reduce the total emission ofsulphur oxides from ships, including both auxiliary and main propulsion engines, to 6.0 gSOx/kWh or less calculated as the total weight of sulphur dioxide emission. Wastestreams from the use of such equipment shall not be discharged into enclosed ports,harbours and estuaries unless it can be thoroughly documented by the ship that suchwaste streams have no adverse impact on the ecosystems of such enclosed ports, harboursand estuaries, based upon criteria communicated by the authorities of the port State to the

    Organization. The Organization shall circulate the criteria to all Parties to theConvention; or

    (c) any other technological method that is verifiable and enforceable to limit SOx emissions toa level equivalent to that described in sub-paragraph (b) is applied. These methods shall beapproved by the Administration taking into account guidelines to be developed by theOrganisation

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    (7) During the first 12 months immediately following entry into force of the present Protocol or of anamendment to the present Protocol designating a specific SOx emission control area under paragraph(3)(b) of this regulation, ships entering a SOx emission control area referred to in paragraph (3)(a) ofthis regulation or designated under paragraph (3)(b) of this regulation are exempted from therequirements in paragraphs (4) and (6) of this regulation and from the requirements of paragraph (5)of this regulation insofar as they relate to paragraph (4)(a) of this regulation.

    6.3.1 General6.3.1.1 The sulphur oxide (SOx) emissions from ships will be controlled by a limit on the

    sulphur content of marine fuel oils, this limit is currently set at 4.5%. In addition afurther limit for the sulphur content of fuel oil, of 1.5%, will exist in SOx EmissionControl Areas. The Baltic Sea will be the first of these areas. Ships operating bothinside and outside the SOx Emission Control Areas will be required to have separatestorage arrangements for two grades of fuel oil and be provided with a means tochange from one grade to the other.

    6.3.1.1.1 When approaching a SOx Emission Control Area the fuel must be changed over tothe 1.5% sulphur content fuel. The change over must completed before entering thecontrol area. The times and the ships' positions at the start and finish of each changeover to and from 1.5% fuel oil must be recorded in a logbook, together with details ofthe bunker tanks and fuel used.

    6.3.1.2 As an alternative to using fuel oil with a 1.5% sulphur content an exhaust gascleaning system or other equivalent system may be used. The cleaning system mustbe capable of reducing the total emissions to within permitted limits25.

    6.3.2 Surveys

    6.3.2.1 Though this regulation is operational, the following initial and periodicalverifications surveys will be made.

    6.3.2.2 Initial Survey

    6.3.2.2.1 Confirming the approved arrangement used on board for compliance with thisrequirement and verifying it has been installed and commissioned.

    6.3.2.2.2 This could be:

    6.3.2.2.2.1 Separate fuel tanks for the two sulphur grades of fuel (4.5% and 1.5%).

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    6.3.2.3.2 Verifying records of fuel change over (times, position and fuel tank capacity) arerecorded in the official log book as relevant.

    6.3.2.3.3 Reviewing the bunker notes to verify the quality of fuel carried onboard is incompliance with the requirements for sulphur content (see Reg. 18).

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    Guidance NotesIssue 002

    September 2004

    6.4 Regulation 15 - Volatile Organic Compounds

    (1) If the emissions of volatile organic compounds (VOCs) from tankers are to be regulated in ports orterminals under the jurisdiction of a Party to the Protocol of 1997, they shall be regulated inaccordance with the provisions of this regulation.

    (2) A Party to the Protocol of 1997 which designates ports or terminals under its jurisdiction in which

    VOCs emissions are to be regulated, shall submit a notification to the Organization. This notificationshall include information on the size of tankers to be controlled, on cargoes requiring vapour emissioncontrol systems, and the effective date of such control. The notification shall be submitted at least sixmonths before the effective date.

    (3) The Government of each Party to the Protocol of 1997 which designates ports or terminals at whichVOCs emissions from tankers are to be regulated shall ensure that vapour emission control systems,approved by that Government taking into account the safety standards developed by theOrganization26 , are provided in ports and terminals designated, and are operated safely and in a

    manner so as to avoid undue delay to the ship.

    (4) The Organisation shall circulate a list of the ports and terminals designated by the Parties to theProtocol of 1997 to other Parties to the Protocol of 1997 and Member States of the Organization fortheir information.

    (5) All tankers which are subject to vapour emission control in accordance with the provisions of paragraph (2) of this regulation shall be provided with a vapour collection system approved by theAdministration taking into account the safety standards developed by the Organization14 , and shalluse such systems during the loading of such cargoes. Terminals which have installed vapour emissioncontrol systems in accordance with this regulation may accept existing tankers which are not fittedwith vapour collection systems for a period of three years after the effective date identified in paragraph(2).

    (6) This regulation shall only apply to gas carriers when the type of loading and containment systemsallow safe retention of non-methane VOCs on board, or their safe return to shore.

    6.4.1 General6.4.1.1 A Vapour Emission Control (VEC) System is an arrangement of piping and hoses

    used to collect the vapours emitted from a tanker's cargo tanks during cargo loadingor ballasting operations for transmission ashore to a vapour processing unit.

    6.4.1.2 The regulations themselves do not require VEC systems to be installed or utilised.

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    conjunction with verification of the VEC system for the US Coastguardsrequirements. A VEC system consists of the following main components:

    A vapour recovery line

    Vapour manifolds

    A closed gauging system

    High level and over fill alarms

    6.4.3 Information to be submitted for plan approvalrequirements

    6.4.3.1 The information in the form of a manual, should, as a minimum, include the itemslisted below. The manual should be submitted in triplicate to an authorised PlanApproval Office, marked for the attention of. The manual will be examined forcompliance with both the USCG standard in 46 CFR Part 39 and the IMO standard inMSC/Circ. 585.

    6.4.3.2 Manufacturer's manuals for individual items of equipment are NOT required,however an adequate description of the equipment should be included describingtype, model ,function, testing and alarm set points etc. (Note:- It is acceptable forseveral of the items listed to be shown on the same plan or drawing).

    6.4.3.2.1 A general arrangement and description of the vapour emission collection systempiping and manifolds including the identification of the manifold as required by 46

    CFR 39 and MSC/Circ. 585.

    6.4.3.2.2 A technical specification and the positions in each tank of the tank gauging devices

    6.4.3.2.3 Details of the level alarms (high and overfill) and their positions in each tank, thetechnical specification of the equipment fitted, which should include the set points(as a percentage of tank capacity) of alarms, means of testing the alarms and thelocation of the audible and visual alarms. A table showing time from overfill alarmset point to tank overfill, time to be not less than 60 seconds.

    6.4.3.2.4 The positions in the vapour line, or in each tank, of the pressure sensing devices(high and low) and details of the system fitted, which should include the alarm setpoints and the location of the audible and visual alarms.

    6.4.3.2.5 Details of the pressure vacuum relief valves including the relief settings and

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    than 25 per cent, which should be agreed with the US Coast Guard, is to be used Thecalculations are to show compliance with 46 CFR 39.30.1 and MSC/circ.585paragraph 2.7.2. The results of the calculations should be shown as a graph or tableshowing liquid transfer rate against the pressure drop.

    6.4.3.2.9 A list of cargoes for which the system is to be used including their vapour pressureand vapour growth rates.

    6.4.3.2.10 If the system is to be used for cargoes which have the potential to polymerise (see15.13 of the International Codes for the Construction and Equipment of ShipsCarrying Dangerous Chemicals in Bulk (IBC Code)), the system is to be of a designthat facilitates detection of polymer build up and details of the means provided areto be described.

    6.4.3.2.11 * Detonation arrestor details.

    6.4.3.2.12 * Oxygen analyser details including sampling and calibration arrangements.

    6.4.3.2.13 * Transfer hose inerting arrangements.

    6.4.3.2.14 The Manual should contain information regarding Training and Transfer Proceduresin addition to the above information, to include the following:

    6.4.3.2.15 A description of the training which each person in charge of a transfer operationutilising a vapour emission control system should have completed. The trainingprogramme should cover the particular system installed on the tanker. The trainingshould encompass the purpose and principles of operation of the vapour emissioncontrol system and provide an understanding of the equipment involved andassociated hazards. In addition the training should provide an understanding ofoperating procedures including testing and inspection of equipment, pre-transferprocedures, piping connection sequence, start-up procedures, normal operations andemergency procedures. Training should also include an understanding of the shoreside terminal equipment and operating procedures.

    6.4.3.2.16 Tanker transfer procedures should contain information on the tanker's vapourcollection system including:

    6.4.3.2.16.1 a line diagram of the tanker's vapour collection piping indicating the locations andpurpose of all control and safety devices;

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    6.4.3.2.17 If a vapour collection system required to meet part 39 is connected to the inert gassystem, the instruction manual required by SOLAS II-2, regulation 62.21 mustinclude procedures relating to vapour collection operations.

    6.4.3.2.18 It is to be confirmed by an electrical Surveyor that level and pressure alarms, audibleand visual alarms, etc., are intrinsically safe and appropriate certification is to besighted on board. For new buildings the local plan approval office should ensure thatthe equipment fitted is intrinsically safe. The appropriate certification should besighted. Where no electrical Surveyor is available then the appropriatedocumentation is to be included in the submission.

    * Items applicable to `service vessels involved in lightening and/or toppingoperations (reference 46 CFR 39.40 ).

    6.4.4

    Initial and Periodical (In Service) Survey6.4.4.1 Verifying that the ship has a Vapour Emission Control system manual or an

    approved tanker transfer procedure containing information on the tanker's vapourcollection system and pressure drop calculations approved for compliance withMSC/Circ.585.

    6.4.4.2 An inspection of the system to ensure that it remains as detailed in the approvedplans of the system as shown in the operations manual or transfer system and that

    the alarms and safety features are operational.

    6.4.4.3 Verifying the vapour collection system piping is electrically continuous and bondedto the hull.

    6.4.4.4 Verifying that the vapour collection system pipe discharge end is readily identifiableto prevent misconnection, and fitted with an isolating valve capable of manualoperation.

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    6.5 Regulation 16. - Shipboard Incineration

    (1) Except as provided in paragraph (5), shipboard incineration shall be allowed only in a shipboardincinerator.

    (2) (a) Except as provided in sub-paragraph (b) of this paragraph, each incinerator installed on boarda ship on or after 1 January 200027 shall meet the requirements contained in appendix IV to

    this Annex. Each incinerator shall be approved by the Administration taking into accountthe standard specifications for shipboard incinerators developed by the Organization28.

    (b) The Administration may allow exclusion from the application of sub-paragraph (a) of thisparagraph to any incinerator which is installed on board a ship before the date of entry intoforce of the Protocol of 1997, provided that the ship is solely engaged in voyages within waterssubjected to the sovereignty or jurisdiction of the State the flag of which the ship is entitled tofly.

    (3) Nothing in this regulation affects the prohibition in, or other requirements of, the Convention on thePrevention of Marine Pollution by Dumping of Wastes and Other Matter, 1972, as amended, and the1996 protocol thereto.

    (4) Shipboard incineration of the following substances shall be prohibited:(a) Annex I, II and III cargo residues of the present convention and related contaminated packing

    materials;

    (b) Polychlorinated biphenyls (PCBs)(c) Garbage, as defined in Annex V of the present Convention, containing more than traces of

    heavy metals: and

    (d) Refined petroleum products containing halogen compounds.(5) Shipboard incineration of sewage sludge and sludge oil generated during the normal operation of a

    ship may also take place in the main or auxiliary power plant or boilers, but in those cases, shall nottake place inside ports, harbours and estuaries.

    (6) Shipboard incineration of polyvinyl chlorides (PVCs) shall be prohibited, except in shipboardincinerators for which IMO Type Approved Certificates have been issued29.

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    (9) Monitoring of combustion flue gas outlet temperature shall be required at all times and waste shall notbe fed into a continuous-feed shipboard incinerator when the temperature is below the minimumallowed temperature of 8500C. For batch-loaded shipboard incinerators, the unit shall be designed sothat the temperature in the combustion chamber shall reach 6000C within five minutes after start-up.

    (10) Nothing in this regulation precludes the development, installation and operation of alternative designshipboard thermal waste treatment devices that meet or exceed the requirements of this regulation.

    6.5.1 General6.5.1.1 The regulations do not require that an incinerator is fitted or that wastes must be

    incinerated. The regulations only control incinerator emission standards when anincinerator is installed on board a ship.

    6.5.1.2 Incinerators installed on or after the 1 January 2000 are to be approved in accordancewith IMO standards32.

    6.5.1.3 The incineration of certain materials that could result in toxic emissions will be

    prohibited, this includes cargo residues from MARPOL Annex I, II and III and anyrelated contaminated packaging, polychlorinated biphenyls (PCBs), garbagecontaining traces of heavy metals and refined petroleum products. Other aspects ofincineration controls already exist in MARPOL 73/78 Annex V and the associatedguidelines for the implementation of that Annex.

    6.5.2 Initial Survey

    6.5.2.1 The survey of the installed incinerator(s) will consist of:

    6.5.2.2 A review of the type approval certificate and verification that a copy of themanufacturer's operating manual is on board.

    6.5.2.3 An inspection of the general condition of the incinerator and tests of the safetysystems.

    6.5.3 In Service (Periodical) survey

    6.5.3.1 This will consist of a visual inspection and operational test with verification of thesafety functions.

    6.5.3.2 Verifying that records are maintained of sludge, waste etc., incinerated, ship'slocation and date Also verifying that the incinerator outlet temperature is

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    6.6 Regulation 17 - Reception Facilities

    (1) The Government of each Party to the Protocol of 1997 undertakes to ensure the provision of facilitiesadequate to meet the :

    (a) needs of ships using its repair ports for the reception of ozone-depleting substances andequipment containing such substances when removed from ships;

    (b) needs of ships using its ports, terminals or repair ports for the reception of exhaust gascleaning residues from an approved exhaust gas cleaning system when discharge into themarine environment of these residues is not permitted under regulation 14 of this Annex;

    without causing undue delay to ships, and

    (c) needs in ship breaking facilities for the reception of ozone-depleting substances and equipmentcontaining such substances when removed from ships.

    (2) Each Party to the Protocol of 1997 shall notify the Organization for transmission to the Members ofthe Organization of all cases where the facilities provided under this regulation are unavailable oralleged to be inadequate.

    6.6.1 Survey

    6.6.1.1 There are no survey requirements for surveyors. It is the sole jurisdiction of the

    Administration to provide suitable facilities at various port locations.

    6.6.1.2 Where an Owner reports to a surveyor, who is acting on behalf of a Flag Administration,details of inadequate facilities at a location, the owner's representative will be requestedto provide a report detailing their concern for either submission to London through thesurveyor or direct to London. London would then submit the report to the flag statesconcerned. Alternatively, the surveyor may advise the owner to send his complaintdirect to the responsible Flag Administration.

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    6.7 Regulation 18 - Fuel Oil Quality

    (1) Fuel oil for combustion purposes delivered to and used on board ships to which this Annex appliesshall meet the following requirements:

    (a) Except as provided in sub-paragraph (b):

    (i)

    the fuel oil shall be blends of hydrocarbons derived from petroleum refining. Thisshall not preclude the incorporation of small amounts of additives intended toimprove some aspects of performance;

    (ii) the fuel oil shall be free from inorganic acid;(iii) the fuel oil shall not include any added substance or chemical waste which either;(1) jeopardises the safety of ships or adversely affects the performance of the machinery,

    or

    (2) is harmful to personnel, or(3) contributes overall to additional air pollution; and

    (b) fuel oil for combustion purposes derived by methods other than petroleum refining shall not:(i) exceed the sulphur content set forth in regulation 14 of this Annex;(ii) cause an engine to exceed the NOx emission limits set forth in regulation 13(3)(a) of

    this Annex;

    (iii) contain inorganic acid; and(iv) (1) jeopardise the safety of ships or adversely affect the performance of the

    machinery, or

    (2) is harmful to personnel, or(3) contribute overall to additional air pollution

    (2) This regulation does not apply to coal in its solid form or nuclear fuels.

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    master or person in charge of the ship to certify that each copy is a true copy of such bunkerdelivery note. The competent authority may also verify the contents of each note throughconsultation with the port where the note was issued.

    (c) The inspection of the bunker delivery notes and the taking of certified copies by the competentauthority under this paragraph shall be performed as expeditiously as possible withoutcausing the ship to be unduly delayed.

    (6) The bunker delivery note shall be accompanied by a representative sample of the fuel oil deliveredtaking into account guidelines to be developed by the Organization. The sample is to be sealed andsigned by the supplier's representative and the master or officer in charge of the bunker operation oncompletion of bunkering operations and retained under the ship's control until the fuel oil issubstantially consumed, but in any case for a period of not less than 12 months from the time ofdelivery.

    (7) Parties to the Protocol of 1997 undertake to ensure that appropriate authorities designated by them:(a) maintain a register of local suppliers of fuel oil;(b) require local suppliers to provide the bunker delivery note and sample as required by this

    regulation, certified by the fuel oil supplier that the fuel oil meets the requirements ofregulations 14 and 18 of this Annex;

    (c) require local suppliers to retain a copy of the bunker delivery note for at least three years forinspection and verification by the port State as necessary;

    (d) take action as appropriate against fuel oil suppliers that have been found to deliver fuel oilthat does not comply with that stated on the bunker delivery note;

    (e) inform the Administration of any ship receiving fuel oil found to be noncompliant with therequirements of regulations 14 or 18 of this Annex; and

    (f) inform the Organization for transmission to Parties to the Protocol of 1997 of all cases wherefuel oil suppliers have failed to meet the requirements specified in regulations 14 or 18 of this

    Annex.

    (8) In connection with port State inspections carried out by Parties to the Protocol of 1997, the Partiesfurther undertake to:

    (a) inform the Party or non-Party under whose jurisdiction bunker delivery note was issued off d li f li f l il i i ll l i f i d

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    6.7.1 General

    6.7.1.1 In addition to limiting the sulphur content of oil fuel there are controls to prevent theincorporation of potentially harmful substances, particularly waste chemicals, intomarine fuel oil. Fuel oil supplied to ships is required to be free from inorganic acids,or chemical wastes that could jeopardise the safety of the ship, be harmful to ships'personnel, or which would contribute overall to additional air pollution. Theaddition of small amounts of additives intended to improve performance is

    permitted.

    6.7.1.2 Bunker suppliers are required to provide ships with a bunker delivery note, givingdetails of the fuel supplied including the product name, density, quantity, its sulphurcontent, and a declaration that the fuel meets the requirements of Annex VI. Thebunker supplier must also provide a truly representative sample of fuel delivered inserviceable containers. The sample must be taken in a proper manner, sealed andsigned by the supplier and the ships officer in charge of bunkering operations

    6.7.1.3 Bunker delivery notes are required to be retained on board for at least three yearsand the fuel sample retained until the fuel is completely used but in any case for notless than 12 months.

    6.7.1.4 The onus is on the bunker supplier to provide fuel of the correct quality and supplyproper samples and documentation. Owners who require their own checks on thefuel supplied can use services such as Lloyds Registers Fuel Oil Bunker Analysisand Advisory Service (FOBAS).

    6.7.2 Survey

    6.7.2.1 The survey will consist of:

    6.7.2.2 Verifying that the bunker delivery notes are on board and retained for at least theprevious three years ( refer also to Reg. 14).

    6.7.2.3 Verifying that bunker samples are being retained onboard for a period of at least 12

    months.

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    6.8 Regulation 19 - Requirements For Platforms And Drilling Rigs

    (1) Subject to the provisions of paragraphs (2) and (3) of this regulation, fixed and floating platforms anddrilling rigs shall comply with the requirements of this Annex.

    (2) Emissions directly arising from the exploration, exploitation and associated offshore processing of sea-bed mineral resources are, consistent with article 2(3)(b)(ii) of the present Convention, exempt fromthe provisions of this Annex. Such emissions include the following:

    (a) emissions resulting from the incineration of substances that are solely and directly the resultof exploration, exploitation and associated offshore processing of sea-bed mineral resources,including but not limited to the flaring of hydrocarbons and the burning of cuttings, muds,and/or stimulation fluids during well completion and testing operations, and flaring arisingfrom upset conditions;

    (b) the release of gases and volatile compounds entrained in drilling fluids and cuttings;(c) emissions associated solely and directly with the treatment, handling, or storage of sea-bed

    minerals; and

    (d) emissions from diesel engines that are solely dedicated to the exploration, exploitation andassociated offshore processing of sea-bed mineral resources.

    (3) The requirements of regulation 18 of this Annex shall not apply to the use of hydrocarbons which areproduced and subsequently used on site as fuel, when approved by the Administration.

    6.8.1 General

    6.8.1.1 Annex VI applies to platforms and drilling rigs unless subject to the above exemptions.

    6.8.1.2 Surveys would follow the format and philosophy of those for ships, taking into account

    the different systems and media employed.

    6.8.1.3 Where further guidance or information is required, this should be addressed to OffshoreServices in the first instance.

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    APPENDIX I

    Extract from Regulation 2, Definition - Ozone-depleting substances

    (6) Ozone-depleting substances means controlled substances defined in paragraph 4 of article 1 of theMontreal Protocol on Substances that Deplete the Ozone Layer, 1987, listed in Annex A, B, C or E to the said

    Protocol in force at the time of application or interpretation of this annex.

    Ozone-depleting substances that may be found on board ship include, but are not limited to :

    Halon 1211 Bromochlorodifluoromethane

    Halon 1301 Bromotrifluoromethane

    Halon 2402 1, 2-Dibromo-1, 1, 2, 2-tetrafluoroethane (also

    known as Halon 114B2)

    CFC-11 Trichlorofluoromethane

    CFC-12 Dichlorodifluoromethane

    CFC-113 1, 1, 2-Trichloro-1,2,2-trifluoroethane

    CFC-114 1,2-Dichloro-1,1,2,2-tetrafluoroethane

    CFC-115 Chloropentafluoroethane

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    APPENDIX II

    (Extract of Annex VI of MARPOL 73/78: Appendix II)

    TEST CYCLES AND WEIGHTING FACTORS

    (Regulation 13)

    The following test cycles and weighing factors should be applied for verification of compliance of marine diesel engines with

    the Nox emission limits in accordance with regulation 13 of MARPOL Annex VI using the test procedure and calculationmethod as specified in the NOx Technical Code.

    1 For constant speed marine engines for ship main propulsion, including diesel electric drive, test cycleE2 should be applied.

    2 For variable pitch propeller sets, test cycle E2 should be applied.3 For propeller-law-operated main and propeller-law-operated auxiliary engines, the test cycle E3 should

    be applied.

    4 For constant-speed auxiliary engines, test cycle D2 should be applied.5 For variable-speed, variable-load auxiliary engines, not included above, test cycle C1 should be applied.

    Test cycle for "Constant-speed main propulsion" Application (incl. diesel-electric drive and variable pitch propellerInstallations)

    Speed 100% 100% 100% 100%

    Power 100% 75% 50% 25%

    Test cycle type E2

    Weighing Factor 0.2 0.5 0.15 0.15

    Test cycle for Propeller-law-operated main and propeller-law-operated auxiliary engine applications

    Speed 100% 91% 80% 63%

    Power 100% 75% 50% 25%

    Test cycle type E3

    Weighing Factor 0.2 0.5 0.15 0.15

    Test cycle for Constant-speed auxiliary engine application

    Speed 100% 100% 100% 100% 100%

    Power 100% 75% 50% 25% 10%

    Test cycle type D2

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    APPENDIX III

    Guidance on Marine Engine On-board Verification Survey.

    INTRODUCTION

    This survey is carried out after installation on board the ship to verify the engine's components,settings and adjustments remain within the limits established at the NOx emission test bed trial (Pre-certification) as recorded in the approved Technical File. Provided these conditions are maintained,the engine is considered to remain operating within the NOx Emission limit for its category, t beingaccepted that if the NOx sensitive components and settings remain the same, then the engine willremain compliant with the NOx emission limits. Thus, it is not necessary to carry out another NOxemission test.

    A verification survey of the engine is required where modifications or adjustments to the designated

    components and adjustable features have been carried out since the last survey. This informationshould be available from the engine's record book of engine parameters37 where all modifications,repairs, adjustments, component replacements, etc., are recorded.

    At each survey the engine would be inspected in accordance with the approved procedure in theTechnical File. The degree of stripping down would be sufficient to allow the NOx sensitivecomponents, settings and adjustments to be verified. In the real word this may not always bepossible, though still desirable, thus we need to consider the tools currently employed for engine

    surveys and use them to our advantage without losing sight of the Surveyors responsibility under hisauthorisation to carry out this statutory survey. Whichever combination of methods are used, theymust provide verification and confidence that the engine remains in compliance.

    The surveyor shall have the option of checking one or all of the identified components, settings oroperating values to ensure that the engine with no, or minor, adjustments or modifications complieswith the applicable emission limits and that only components of the current specification are beingused. Where adjustments and/or modifications in a specification are referenced in the technical file,they must fall within the range recommended by the manufacturer and approved by the

    Administration..

    Where a combination of methods are used to verify compliance, such methods will be applied withdue care and diligence by surveyors who through experience understand the techniques along withtheir limitations.

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    Survey Methods.

    Warning, this is not a list of acceptable alternatives to direct survey, but methods which may beutilised periodically in conjunction with the direct surveys while still maintaining confidence in theengine's compliance.

    The Technical Code Procedure. (This will always be the preferred method).

    The Technical Code specifies requirements for the on-board verification survey.

    Documentation Review. A review of the documentation for each engine which includes theengine parameter book to ensure the components, settings and adjustments recorded remainwithin the designated limits. This may be supported by the engine log book.

    Carrying out the on-board verification survey in accordance with the procedure provided in theengine's NOx Technical File.

    Where an engine is provided with an after treatment device such as an SCR (Selective CatalyticReduction) system, a check of its operation forms part of the survey. This holds true for otherNOx abatement systems such as for injection of water, steam, etc., into the cylinder or fuel to aidcombustion.

    Additional Survey Tools.

    These may be used in conjunction with the direct survey procedure to limit the degree of opening upat intermediate surveys. For renewal surveys, it is recommended the full survey is conducted.

    Classification surveys. Allows verification inspection of NOx sensitive components while theengine is open (dismantled) for survey. This can be a very useful tool provided the verification isthorough and the information properly recorded in the survey report such that it is available foruse at future surveys.

    Operational test under load. Allows comparison and assessment of the engine operatingparameters against those in the approved NOx Technical File. This could be used to limit thedegree of opening up required after confirming the easily accessible components and settings areacceptable. Useful for the smaller engines driving pumps, etc. Also for generators which are inoperation, where it is not feasible to carry out the full direct inspection.

    E i L B k R i i th i l b k d t f th t f th id

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    The following provides a general guide for some of the main components, settings and adjustments,which may be encountered during a survey38. When carrying out the survey, the surveyor will usethe On-board NOx verification survey procedure provided in the approved NOx Technical File, whichlists the specific information and data for the engine under survey.

    Combustion Chamber and Compression Ratio

    The approved on-board survey method will define how to carry out the inspection/verification of

    the various parameters or parts and can vary between manufacturers. The following are provided asguidelines where this is not clear or alternatives may be considered.

    Verifying the cylinder head, piston, piston rod (connecting rod) and shims where relevant, would bethe normal method used. However, the compression ratio may be checked by taking compressionreadings for each or selected cylinders. Other means are to check the travel of the piston and toverify that the correct shims have been used where applicable. Care must be taken, since the wrongtype of cylinder head or piston could alter the combustion space characteristic geometry, i.e. flow /

    swrill. This may not be easily observed from travel measurements only. Variations in thecombustion space / geometry can have an effect on the NOx emissions produced due to changes inthe combustion process.

    Cylinder Head

    Normally identified by its identification number (ID), which is usually in an accessible positionwithout opening up.

    The NOx emissions may be altered if the combustion chamber geometry of the cylinder head is

    modified, affecting NOx formation mechanism and therefore emission characteristics.

    ID Number

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    Turbo-chargers

    Turbo-chargers are sized to suit the engine power and operating characteristics. Therefore changesto their component parts (impellers, diffuser, etc.) will affect the combustion and hence the NOxemissions. Each major component is marked and at classification surveys their NOx identificationnumber should be verified. Then at periodical Annex VI surveys it would be sufficient to verify thecorrect type of turbo-charger is fitted provided no modification had been carried out. Modification

    details can be confirmed from the records in the engine book of engine parameters.

    ID Number

    Turbo-charger IDnumber

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    Charge Air Cooler and Cooling System

    The temperature of the cooling water controls the temperature of the combustion air, which has acontrolling effect on the engine combustion and thus the products of combustion. The cooler istherefore sized to ensure optimum engine operating parameters with a sea water temperature of25C. Hence the importance of verifying the cooler is the correct one for the engine. This can bechecked by the ID on the cooler nameplate. The cooler should be maintained in good condition with

    effective sealing between the two media.

    Note: The Technical File is approved for a particular cooling system and associated temperature setpoints. Always consult the approved survey procedures for that engine.

    Fuel Injection, Timing and Timing Control System

    The injection timing, the injector nozzle, injection pump or the fuel cam, all affect the NOx emissioncharacteristics or an engine.

    The injector nozzle will be marked with the ID on the nozzle. This is easy to remove and check. It isimportant since a different number and/or size of holes in the nozzle can affect the combustion and

    hence the NOx emissions. Also an incorrectly set injector opening pressure can affect thecombustion. This may be identified from the exhaust temperatures and indicator cards. Withregular maintenance this should not present a problem.

    Cooler IDnumber

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    The fuel pumps may be in a block or individual depending on the engine type and configuration.The fuel may be delivered via a common rail or by individual pumps to each injector with theinjector opening and closing by either electronic or mechanical control. The fuel pumps are markedwith an identifier and type designation, which may be checked without dismantling completelydepending on the type fitted. For some pumps, the plunger travel is measured by a special tool afterremoval of the discharge pipe while for others it is possible to verify by removal of the side plugs andturning the engine over to note the discharge and cut-off points in relation to the camshaft markings.Electronic control units have an ID number and are normally sealed. Where adjustments are

    required, these may only be made by an authorised manufacturer's representative.

    Note: Fuel Pumps in the common rail system are not defined as NOx sensitive components.

    Injection timing depends on the system employed. Many of the smaller engines (Member's offamily) use pre-set electronic timing, which cannot be adjusted by the ship's staff.

    In other engines, (e.g. members of an engine group) the timing can be altered by re-positioning thecamshaft, the timing chain, drive wheels or fuel cam or its profile or software parameters in commonrail applications. These items are all marked with an identifier plus the original settings to facilitate

    verification checks. They can normally be reviewed by the removal of a cover and turning the engineto the correct position in accordance with the approved procedure.

    MARPOL ANNEX VI I 002

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    APPENDIX IV

    (Extract of Appendix III from Annex VI of MARPOL 73/78)

    CRITERIA AND PROCEDURES FOR DESIGNATION

    OF SOx EMISSION CONTROL AREAS

    (Regulation 14)

    1 OBJECTIVES1.1 The purpose of this appendix is to provide the criteria and procedures for the designation of SOx

    Emission Control Areas. The objective of SOx Emission Control Areas is to prevent, reduce, andcontrol air pollution from SOx emissions from ships and their attendant adverse impacts on land andsea areas.

    1.2 A SOx Emission Control Area should be considered for adoption by the Organization if supported bya demonstrated need to prevent, reduce, and control air pollution from SOx emissions from ships.

    2 PROPOSAL CRITERIA FOR DESIGNATION OF SOx EMISSION CONTROL AREAS2.1 A proposal to the Organization for designation of a SOx Emission Control Area may be submitted

    only by contracting States to the Protocol of 1997. Where two or more contracting States have a

    common interest in a particular area, they should formulate a co-ordinated proposal.

    2.2 The proposal shall include:2.2.1 a clear delineation of the proposed area of application of controls on SOx emissions from ships,

    along with a reference chart on which the area is marked;

    2.2.2 a description of the land and sea areas at risk from the impacts of ship SOx emissions;2.2.3 an assessment that SOx emissions from ships operating in the proposed area of application of the

    SOx emission controls are contributing to air pollution from SOx, including SOx deposition,and their attendant adverse impacts on the land and sea areas under consideration. Suchassessment shall include a description of the impacts of SOx emissions on terrestrial and aquaticecosystems, areas of natural productivity, critical habitats, water quality, human health, andareas of cultural and scientific significance, if applicable. The sources of relevant data includingmethodologies used, shall be identified;

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    2.3 The geographical limits of an SOx Emission Control Area will be based on the relevant criteria

    outlined above, including SOx emission and deposition from ships navigating in the proposed area,traffic patterns and density, and wind conditions.

    2.4 A proposal to designate a given area as an SOx Emission Control Area should be submitted to theOrganization in accordance with the rules and procedures established by the Organization.

    3 PROCEDURES FOR THE ASSESSMENT AND ADOPTION OF SOx EMISSION CONTROLAREAS BY THE ORGANIZATION

    3.1 The Organization shall consider each proposal submitted to it by a contracting State or contractingStates.

    3.2 A SOx Emission Control Area shall be designated by means of an amendment to this Annex,considered, adopted and brought into force in accordance with article 16 of the present Convention.

    3.3 In assessing the proposal, the Organization shall take into account the criteria which are to be includedin each proposal for adoption as set forth in section 2 above, and the relative costs of reducing sulphurdepositions from ships when compared with land-based controls. The economic impacts on shippingengaged in international trade should also be taken into account.

    4 OPERATION OF SOx EMISSION CONTROL AREAS4.1 Parties which have ships navigating in the area are encouraged to bring the Organization any

    concerns regarding the operation of the area.

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    APPENDIX V

    (Extract of Appendix IV from Annex VI of MARPOL 73/78)

    TYPE APPROVAL AND OPERATING LIMITS

    FOR SHIPBOARD INCINERATORS

    (Regulation 16)

    (1) Ships incinerators described in regulation 16(2) shall possess an IMO type approval certificate for eachincinerator. In order to obtain such certificate, the incinerator shall be designed and built to an approvedstandard as described in regulation 16(2). Each model shall be subjected to a specified type approval testoperation at the factory or an approved test facility, and under the responsibility of the Administration,

    using the following standard fuel/waste specification for the type approval test for determining whetherthe incinerator operates within the limits specified in paragraph (2) of this appendix:

    Sludge Oil Consisting of: 75% Sludge Oil from HFO;

    5% Waste Lubricating Oil; and

    20% Emulsified Water

    Solid Waste consisting of: 50% Food Waste50% Rubbish Containing

    Approx. 30% Paper,

    " " 40% Cardboard,

    " " 10% Rags,

    " " 20% Plastic

    The mixture will have up to 50% moisture and7% incombustible solids

    (2) Incinerators described in regulation 16(2) shall operate within the following limits:

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    APPENDIX VI

    (Extract of Appendix V from Annex VI of MARPOL 73/78)

    Information to be included in the bunker delivery noteRegulation 18(3)

    Name and IMO number of receiving ship

    Port

    Date of commencement of delivery

    Name, address, and telephone number of marine fuel oil supplier

    Product name(s)

    Quantity (metric tons)

    Density at 150 C (kg/m3))39

    Sulphur content (% m/m)40

    A declaration signed and certified by the fuel oil supplier's representative that the fuel oil

    supplied is in conformity with regulation 14(1) or (4)(a) and regulation 18(1) of this Annex.

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    APPENDIX VII

    Frequently Asked Questions

    MARPOL Annex VI and the NOx Technical Code.

    NOTE: Frequently asked questions relating to Regulation 13,Certification of Marine Diesel Engines for compliance with the NOx

    Emission limits, are contained in a separate document:

    "Emissions of Nitrogen Oxides from Marine Diesel Engines Questions andAnswers"

    Available on the LR Internet site : Path -

    http://www.cdlive.lr.org/mainmenu.asp/ then Approvals Lists,NOx Emissions

    ABCD

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    ABCDQ Which regulations are required to be complied with?A If a statement of fact is requested then it is the Owners option which regulations are

    complied with.

    If an IAPP certificate or statement of compliance is requested then all the regulations asapplicable for the ship type and equipment fitted are required to be complied with: -

    Regulation 12

    Regulation 13 (if diesel engine > 130kW are fitted)

    Regulation 14

    Regulation 15 (tankers only and if VEC system fitted)

    Regulation 16 (if incinerator fitted)

    Regulation 18

    Q How will Air Pollution from ships be controlled?A Annex VI controls six areas of air pollution from ships: --

    A prohibition on the discharge of ozone depleting substances

    Emissions of nitrogen oxides -NOx

    Emissions of sulphur oxides - SOx.

    Volatile organic compound emissions from tankers

    Incinerators emission controls

    Fuel oil quality

    Q What certification can LR offer?

    A If requested by a shipbuilder or an Owner, LR can offer the following certification andsurveys.

    A statement indicating the degree to which a ship complies with the MARPOLAnnex VI Regulations which were verified at the Owners' request.

    This would be a statement of fact stating the ship had been surveyed, with details of theregulations it complies with at the time of survey. The statement would have no period ofvalidity and no further surveys would be required

    ABCD

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    ABCDQ Can LR issue certification on behalf of national administrations?

    A Most administrations have indicated that LR can issue Annex VI certification on theirbehalf. Other administrations have indicated that an LR certificate or statement ofcompliance would be sufficient evidence of compliance to issue an IAPP certificate onceAnnex VI comes into force. This would be issued either by the Administration or on theirbehalf by an authorised representative. Surveyors will determine any additional or specificFlag requirements prior to commencement of a survey.

    Q Can an IAPP certificate be issued?

    A IAPP certificates can be issued when MARPOL Annex VI comes into force on 19 May 2005.One notable exception is for UK Flag ships, where IAPP certificates should be issued assoon as possible. In the interim period Interim IAPP Statements or Certificates ofCompliance can be issued.

    Q Can LR certify diesel engines for compliance with the NOx Technical Code?

    A Yes. However, procedures for NOx Code certification are not dealt with in theseguidelines41.

    If a request is received for NOx Code certification, contact Design Appraisal (DAPP)Engineering Systems, London Plan Approval for instructions.

    ABCD

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    ABCDAPPENDIX VIII

    Annex VI Survey Requirement Map

    Reg 13NOx

    Reg16Incinerator

    Reg 18Fuel

    Quality

    Reg 12Ozone-

    depletion

    Reg 14SOx

    Reg 15VOC

    Initial on-board survey &issue IAPP Certificate

    Annual / Intermediate SurveyEndorse IAPP Certificate

    TypeApprovalCertificate

    EIAPPCertificate or

    InterimEIAPP

    Design Appraisal Document Bunker Note+ Sample

    Plan AppraisalPlan Appraisal &Manufacturing Inspection,

    Test & Certification

    ABCD

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    ABCDAPPENDIX IX

    AIR POLLUTION PREVENTION,

    SURVEY REPORT (Provisional) and CHECK LIST

    Page 1 of 1

    AB DAIR POLLUTION PREVENTION, SURVEY REPORT (Provisional)

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    ABCDAIR POLLUTION PREVENTION, SURVEY REPORT (Provisional)

    This report and any certificates or statements issued are for the information of interestedparities to indicate compliance with the provisions of MARPOL Annex VI.

    PART A

    NAME OF SHIPIMO

    NUMBERNATIONALITY AND PORT OF

    REGISTRYGROSS

    TONNAGEDATE KEEL

    LAID

    PORT REPORT NUMBER FIRST VISIT LAST VISITNUMBER OF

    VISITS

    FEES EXPENSESTOTAL FEES AND

    EXPENSES

    PART B

    1.0 I/We have carried out a MARPOL 73/78 Annex VI Survey on the above-mentioned ship. The survey carried out was:-

    1.1 An Initial/Periodical (Renewal)* survey - The survey was/was not* completed 1.2 An Annual survey.- The survey was/was not* completed

    1.3 An Intermediate survey - The survey was/was not* completed 1.4 A general examination for: Change of Class/ Change of Flag/ Other (state reason)* 1.4 Previous Certificate full term/interim * 1.4.1 Report. Number Issue date Expiry date

    1.5The undersigned has verified the equipment and arrangements in the Record of Construction and Equipment and foundthem to be in agreement, well maintained and in an efficient and good condition.

    1.5.1 A full term Certificate/Statement of Compliance* valid for a period of 5 years has/has not been issued. 1.5.2 If no full term certificate issued state reason (e.g Survey not completed or deficient equipment etc.) 1.5.3

    An interim / interim conditional certificate has been issued. (Outstanding to be listed in the narrative of thereport)

    1.5.4 A statement detailing the extent of compliance has been issued 1.6 Certificate/Statement details Issue date Expiry date1.6.1 Without Conditions With Conditions

    2A mandatory Annual/Intermediate * survey in accordance with Regulations 5(1) and (4) of MARPOL Annex VIhas been carried out and the Ship found to comply with the relevant provisions of the Convention and the

    Certificate has been endorsed.

    3 A survey checklist has been completed (as applicable) in all respects and is retained in this office.

    3.1The relevant amended pages of the Record of Construction and Equipment are / have been forwarded toLondon

    3.2Copies of Certificates/Statements, Reports, and advice of Survey as applicable have been forwarded to thenational authorities.

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    ABCD

    MARPOL 73/78 ANNEX VI

    SURVEY CHECK LIST (Provisional)This survey checklist and any certificates or statements issued are for the information ofinterested parties to indicate compliance with the provisions of MARPOL Annex VI.

    Mark Yes, No or NA as applicable.The right hand column indicates the survey type for which item to be completed.Complete all sections A to as applicable

    AA - GENERAL

    AA.1 Have any changes been made or any new equipment installed which would affect the validity of theCertificate? (If Yes, include details in the narrative of the report).

    Yes/No* A/I/R

    AA.2 Were all other Statutory Certificates and Classification Certificates valid at the time of survey? Yes/No* A/I/R

    AA.3Was the structure, equipment, systems, fittings arrangements and materials examined for compliance withthe relevant requirements of MARPOL 73/78 Annex VI?

    Yes/No* A/I/R

    BB - DOCUMENTATION

    BB.1Are there certificates for compliance with the NOx Technical Code onboard for each engine required to becertified (refer to section 2.2.1 of the Record of Construction and Equipment).

    Yes/No/NA* A/I/R

    BB.2 Is there an approved Technical file for each Certified engine on board? Yes/No/NA* A/I/R

    BB.3 Is there a type approval certificate on board for each incinerator onboard? Yes/No/NA* A/I/R

    BB.4 Are there bunker delivery notes on board as required by regulation 18? Yes/No/NA* A/I/R

    BB.5 Is there an approval certificate for the exhaust gas cleaning system? Yes/No/NA* A/I/R

    CC.- OZONE DEPLETING SUBSTANCES (REGULATION 12)

    CC.1 Does any system or equipment onboard contain ozone depleting substances? Yes/No* A/I/R

    Cc.1.1 If Yes, Check Dates Such Equipment Are Permitted To Remain Onboard. Yes/No/NA* A/I/R

    Cc.1.2Is Any System Or Equipment Still In Use Or Approaching Its Allowable Date To Remain Onboard?If Yes, Advise Owners It Must Be Removed And Disposed Of To Appropriate Reception Facilities.

    Yes/No/NA* A/I/R

    DD - Nitrogen Oxide Emissions From Diesel Engines (Regulation 13).Use 1, 2 Or 3 Dependant Upon The Method Indicated In The Approved Technical File.

    DD.1 Verification Of The Engine Parameter Check Method : Yes/No/NA* A/I/R

    DD.1.1 Review Engine Documentation And The Record Book Of Engine Parameters Yes/No/NA* A/I/R

    DD.1.2 Has The Engine Undergone Any Modifications Or Adjustments Since Last Surveyed? Yes/No/NA* A/I/R

    DD.1.3 Conduct survey as detailed in the on-board system in the Technical File. Yes/No/NA* A/I/R

    DD.1.4 If An Electronic Engine Management System Is Used Check Against The Original Settings. Yes/No/NA* A/I/R

    DD.2 Verification Of The Simplified Measurement Method. Yes/No/NA* A/I/R

    DD.2.1 Review Engine Documentation. Yes/No/NA* A/I/R

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    DD.3.5 Review and confirm the past three month's engine operating data. In accordance with the Technical File. Yes/No/NA* A/I/R

    DD.4 After-treatment device is installed. Yes/No/NA* A/I/R

    DD.4.1 From an external examination verify the after-treatment device is in a generally satisfactory condition. Yes/No/NA* A/I/RDD.4.2 Verify it's operation and NOx compliance Yes/No/NA* A/I/R

    DD.4.3 If additional substances are introduced (e.g. steam, water, urea, etc) verify consumption meter operation. Yes/N-/NA* A/I/R

    DD.4.4Confirm any adjustments or modifications are recorded in the Engine s Record Book of engineparameters.

    Yes/NO/NA* A/I/R

    DD. 4.5Where adjustments or modifications are outside the Technical file limits, confirm they have been verifiedas not exceeding the NOx limits.

    Yes/No/NA* A/I/R

    EE - SULPHUR OXIDES -( REGULATION 14)

    EE.1 From an external examination verify the exhaust cleaning system is generally in a satisfactory condition.. Yes/No/NA* A/I/R

    EE.2 Is the exhaust cleaning system is operating correctly with manufacturer's instructions? Yes/No/NA* A/I/R

    EE.3Are there records of the changeover to and from low sulphur fuel during transit through SOx EmissionControl Areas?

    Yes/No/NA* A/I/R

    EE.4Where equipped with tanks for low and normal sulphur content fuel are switching arrangements providedand operational?

    Yes/No/NA* A/I/R

    EE 5 Review bunker notes for carriage of correct quality fuel(s) Yes/No/NA* A/I/R

    FF - VOLATILE ORGANIC COMPOUNDS (REGULATION 15)FF.1 From a general examination, was the vapour collection piping in a satisfactory condition? Yes/No/NA* A/I/R

    FF.2Is a means provided to eliminate the collection of condensate in the system, such as drains in low points ofthe line end, and are the drains operable?

    Yes/No/NA* A/I/R

    FF.3 Is the piping electrically continuous and electrically bonded to the hull, and the means of bonding intact? Yes/No/NA* A/I/R

    FF.4Are the isolation valves at the vapour manifolds operational and do the valve position indicators operatecorrectly?

    Yes/No/NA* A/I/R

    FF.5 Are the ends of each line properly identified as vapour lines? Yes/No/NA* A/I/R

    FF.5.1 Are the vapour connections flanges in accordance with industry standards? Yes/No/NA* A/I/R

    FF.6 Where portable vapour hoses are provided are they in good condition, and electrically continuous? Yes/No/NA* A/I/R

    FF.6.1 Are the hose ends properly marked as vapour hoses? Yes/No/NA* A/I/R

    FF.7 Is the closed gauging system operational and the readouts in the cargo control area functional? Yes/No/NA* A/I/R

    FF.8 Is an overflow control system provided? (level alarms) Yes/No/NA* A/I/R

    FF.8.1 Are the alarms operational? Yes/No/NA* A/I/R

    FF.8.2 Do the audible and visual alarms operate? Yes/No/NA* A/I/R

    FF.8.3 Are the alarms properly labelled? Yes/No/NA* A/I/R

    FF.8.4 Does the power failure alarm operate? Yes/No/NA* A/I/R

    FF.8.5 Is there a means to check the operation of the alarms and is this means operational? Yes/No/NA* A/I/R

    FF.9 Are high and low pressure alarms provided in each main vapour line? Yes/No/NA* A/I/R

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    GG.2.3 Combustion chamber negative pressure Yes/No/NA* A/I/R

    GG.2.4 Flame safeguard control, alarms and shutdowns. Yes/No/NA* A/I/R

    GG.2.5 All alarms both visual, audible and functioning and do they indicate the cause of the failure Yes/No/NA* A/I/RGG.2.6 Power loss alarm and auto shut down arrangements Yes/No/NA* A/I/R

    GG.2.7 Charging arrangement Yes/No/NA* A/I/R

    GG.2.8 Low fuel oil pressure alarm/shut down Yes/No/NA* A/I/R

    GG.2.9 Emergency stop switch and electrical isolating arrangements Yes/No/NA* A/I/R

    GG 2.10 Interlocks Yes/No/NA* A/I/R

    GG.3 Was it verified that the O2 content in the combustion chamber is between 6 12% Yes/No/NA* A/I/R

    GG.4 Are complete instruction and maintenance manuals available on board? Yes/No/NA* A/I/R

    GG.5 Are Staff suitably trained? Yes/No/NA* A/I/R

    GG.6 Are drip trays fitted under each burner, pump, strainer and are they in good condition? Yes/No/NA* A/I/R

    CC.7 Was the combustion chamber flue gas outlet temperature verified as between 850 1200 o C? Yes/No/NA* A/I/R

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