marpolannex vi-imo

MARPOL Annex VI –Regulations for the prevention

of air pollution from ships

Edmund Hughes

Marine Environment DivisionIMO

REMPEC Regional Workshop on the ratification and implementation

of MARPOL Annex VI, Athens, Greece 26-27 October 2010

Overview

• Introduction - IMO & MARPOL Annex VI

• Regulations

• Enforcement

• Other relevant IMO resolutions

• Future developments

• Questions?

International Maritime Organization (IMO)

• The IMO Convention was adopted in 1948 and IMO first met in 1959

• A specialized agency of the UN

• 169 Member States

• Develop and maintain a comprehensive regulatory

framework for shipping

• Safety, environment, legal matters,

technical co-operation, security and the efficiency of shipping

Safe, secure and efficient shipping on cleaner oceans

Shipping affects us all........

• ~90% of world trade is carried by sea

– Raw materials and commodities

– Finished goods

– Foodstuffs

– Fuel

• Underpins global economy

• Important to remain a safe, secure, environmentally friendly and energy efficient transport system

MARPOL Annex VI – Regulations for the

Prevention of Air Pollution from Ships

Entered into force 19 May 2005

Revisions to Annex VI

Adopted October 2008 and

entered into force 1 July 2010

Annex VI - Application Summary

Application All Ships

Does not apply

• When suffering damage to ship or equipment

• When saving life at sea

• When securing safety of ship

Surveys and Certification

Subject to Initial, Annual,

Intermediate, and Renewal surveys

International Air

Pollution Prevention (IAPP) Certificate• Ships constructed before 19 May 2005

• Comply no later than 1st drydock but no later than 3 years after entry into force

• All ships of ≥ 400 gross tonnage

• Fixed or floating platforms (drilling rigs)• Floating craft and submersibles

MARPOL Annex VI – Regulations

Ozone depleting substances (ODS) Reg.12

Nitrogen oxides (NOx) Reg.13

Sulphur oxides and Particulate Matter (SOx) Reg.14

Volatile organic compounds (VOC) Reg.15

Shipboard incineration Reg.16

Reception Facilities Reg.17

Fuel oil quality and availability Reg.18

MARPOL Annex VI

Regulation 12

Ozone Depleting Substances

Montreal Protocol – Prevention of Ozone Depletion

• Entered into force 1 January 1989

• Due to its widespread adoption and implementation it has been hailed as an

example of exceptional international co-operation with Kofi Anan quoted as saying that "perhaps the single most successful international agreement to

date has been the Montreal Protocol“. It has been ratified by 196 states.

• Gases considered in terms of Ozone Depletion Potential (ODP):

– The ODP is based on the amount of chloride which is released by the

refrigerant as it degrades.

– As the refrigerant decomposes the free chlorine released acts as a

catalyst in the complex chemical reaction which leads to the destruction of the ozone.

– The ODP figure given for each refrigerant is relative to the ODP of CFC

R11 which is taken as 1.

R11ODP = 1.0

GWP = 4000

R12ODP = 0.9

GWP = 8500

R115(R502)

ODP = 0.283GWP = 5591

CFCChlorofluorocarbon

Production Ban 1996Article 5 countries 2010

R22ODP = 0.055GWP = 1700

R141b(Foam blow)ODP = 0.11GWP = 630

HCFCHydrochlorofluorocarbonTransitional Substance

Banned in new plant

R410AODP = 0

GWP = 1890(High Pressure)

R404AODP = 0

GWP = 3748(High GWP)

R507ODP = 0

GWP = 3800(High GWP)

R407CODP = 0

GWP = 1610(Flammability?)

HFCHydrofluorocarbon

Ozone FriendlyUnder question

AmmoniaODP = 0

GWP = <1

CarbonDioxideODP = 0

GWP = 1.0

Propane/Isobutane

ODP = 0GWP = 3.0

EnvironmentallyInert

Natural Substances

Refrigerants - Family Tree

ODP – Ozone Depleting PotentialGWP – Global Warming Potential

ODS – Regulation 12• Does not apply to sealed units (Reg.12.1)

• Deliberate emissions prohibited (Reg.12.2)

• Other than Hydrochloroflurocarbon (HCFC) all other ODS

banned in new ships from 19 May 2005 (Reg.12.3.1)

• HCFC banned in new ships from 1 Jan 2020 (Reg.12.3.2)

• Delivery to reception facilities following removal (Reg.12.4)

• Supplement to IAPP lists equipment containing ODS

(Reg.12.5)

• Required to complete an ODS record book approved by

Administration (Reg. 12.6)

– Recharge, repair or maintenance of equipment

– Discharge (deliberate or not), delivery to reception

facilities, supply

Effects of ODS Regulation 12

• Phase out of CFC and HCFC refrigerants

• Non availability of supplies of older gases

• Move to alternative refrigerant types

– natural substances – carbon dioxide, ammonia, propane and cyclo-pentane

– possible safety considerations, toxicity, flammability

• Alternative technologies – Peltier effect

MARPOL Annex VI

Regulation 13 &

NOx Technical Code

Prevention of

Nitrogen Oxides emissions

NOx emissions Regulation 13

• Which engines need to comply?

• Engine certification?

• Onboard NOx verification methods?

• Alternative methods of compliance?

Regulation 13 - Application

Applies toinstalled on a ship

constructed on or after

1st January 2000

Diesel

engines

with a power

output more than 130 kW

Applies to

which undergo a major conversion on or after

1st January 2000

Diesel

engines

with a power

output more

than 130 kW

Not applicable to

• Emergency diesel engines

• Engines installed in lifeboats

• Any device or equipment intended to be

used solely in case of emergency

Tier I * - Ships constructed 1 Jan 2000 to 31 Dec 2010

Tier II - Ships constructed 1 Jan 2011 to 31 Dec 2015

Tier III ** - Ships constructed 1 Jan 2016 onwards

*NOx limit in original Annex VI ** Within ECA

Tier n < 130 rpm 130 ≤ n < 2000 rpm n ≥ 2000 rpm

I 17.0 g/kWh 45.0*n(-0.2) g/kWh 9.8 g/kWh

II 14.4 g/kWh 44.0*n(-0.2) g/kWh 7.7 g/kWh

III 3.4. g/kWh 9.0*n(-0.2) g/kWh 2.0 g/kWh

n = rated engine speed – crankshaft rpm

NOx emission limits

Ships constructed - 1 Jan 1990 to 31 Dec 1999

Required to fit an “approved method” to enable the engine to meet Tier I limits.

IMO to be notified of approved method

The approved method to be installed at first renewal survey 12 months after IMO notified the “method” is approved

Tier n < 130 rpm 130 ≤ n < 2000 rpm n ≥ 2000 rpm

I 17.0 g/kWh 45.0*n(-0.2) g/kWh 9.8 g/kWh

NOx emission limits – Approved Method

NOX Emissions Regulation 13

Engine NOx emission engine certification

• Test bed exhaust emission measurement

• NOx Technical File

• information on components, settings, operating values &

adjustments to maintain NOx emissions within allowable limits

• Issue of Engine International Air Pollution Prevention (EIAPP) certificate or statement of compliance

• applicable to all engines over 130Kw where Regulation 13 applies

• valid for the engine’s life

• Onboard verification (components or measurement) initially


Onboard NOx Verification Methods:

• Engine Parameter check method

check engine components, settings and operating values against NOx Technical File

• Simplified Measurement method

confirmation test of NOx emissions to be within the limits of respective emissions measured on the test bed

• Direct Measurement and Monitoring method

direct measurement of the exhaust flow by flow nozzle or equivalent metering system; difficulties in terms of direct gaseous flow measurement; potential errors


Alternative methods of compliance:

• Exhaust gas cleaning systems (same issues for SOx)

– Systems being tested but currently no approved exhaust gas cleaning method on market

• Other equivalent method approved by the Administration for NOx emission reduction e.g. recirculation

• IMO informed of first “approved method” by Denmark on 5 October 2010

MARPOL Annex VI

Regulation 14

Sulphur Oxides (SOx) and Particulate Matter

(SOx a cause of acid rain, sea and soil acidification

Particulate Matter – harmful to human health)

Regulation 14 - Sulphur Oxides and

Particulate Matter

2005-2010 sulphur limits for fuel oil

• World wide - 4.5% on any fuel used on board ships

• SECA (Sulphur Emission Control Area) - 1.5%

• Permitted to use an exhaust gas cleaning system

to reduce total emissions of SOx to 6.0g/kWh


Particulate Matter

Revised Annex VI - World wide limits from:

1 January 2012 sulphur content not to exceed 3.50%

then either:


or

1 January 2025, subject to a review of fuel availability to be completed by 2018

Emission Control Area sulphur limits

1 July 2010 sulphur content not to exceed 1.00%

then


Exhaust gas cleaners/Emission Abatement Technologies

Permitted World wide and in ECA under Reg.4 – Equivalents

(Equivalence option limited to Parties)


Particulate Matter

East of 5 W

East of 4 W

South of 62o N

North Sea

Baltic

Sea

Mongstad

Bergen

Falmouth

57o.44’.08 N

Sulphur Emission Control Areas

• Baltic Sea - 19 May 2006 (SOx)

• North Sea and English Channel - 21 November 2007 (SOx)

More ECA are likely to be proposed in the future

Operational/Design matters

• Fuel system segregation – storage capacity/tanks

• Segregated cylinder lube oil tanks may be required to cover the

different range of sulphur content fuels

• Sufficient time for fuel change over is required prior to entry into

an Emission Control Area

• Recording procedures in log book and monitoring (Reg.14.6)

• More complex system and therefore more susceptible to errors -

an Integrated Fuel Management System will be essential

• Planning of voyages – selection of bunker ports and trade routes

to ensure correct fuel onboard prior to entering an ECA

(Reg.18.2.1.1)

Emission Control Areas – SOx & NOx• North American – enters into force on 1August 2011

• Puerto Rico & US Virgin Islands (adoption at MEPC 62?)

Exhaust Gas Cleaning Systems• An alternative to low SOx fuel

• Compliance demonstrated on the basis of the SO2(ppm)/CO2(% v/v) ratio

• Guidelines MEPC.184(59)

• Considerations: space, initial cost, availability

• Operation and maintenance

• Class/Port Authorities inspection required

• Party to approve

Exhaust Gas Cleaning Systems

• Extensive research currently underway

• A number of systems being considered/tested

• Trial results show emissions reduction in the order of 90+%

• Shown to be effective at reducing SOx, particulates and other harmful gases

Emissions* Efficiency*

SOx 90+%

NOx 5%

Particulates 80%

*Source: Exhaust Gas Cleaning Systems Association

(Represents 10 manufactures )

MARPOL Annex VI

Regulation 15

Volatile Organic Compounds

(affect the environment and human health)

VOCs - Regulation 15

• Oil cargoes give off VOCs

• Controls on volatile emissions from tanker cargo tanks during loading/ unloading of oil cargoes

• Vapour Emissions Control System (VECS) to be compliant with MSC/Circ. 585 on Standards for VECS systems

• Crude oil tankers to have an approved VOC manual (does not apply to gas carriers - Reg. 15.7 )

VOCs - Regulation 15• For Parties applying Regulation 15 in port(s) and terminal(s):

– Shall submit notification to IMO 6 months before effective date (Reg.15.2)– Shall take into account IMO safety standards for Vapour Emission Control Systems

(VECS) (MSC/Circ.585) (Reg.15.5)

• IMO shall circulate list of ports and terminals (Reg.15.4)

• Tankers need to install a VECS approved by Administration (Reg.15.5)

• Ports/terminals with approved VECS can accept tankers without VECS

for up to 3 years after effective date (Reg.15.5)

• Tankers need to develop and implement a VOC management plan

approved by the Administration (Reg.15.6)

– Procedures for minimizing VOC emissions during loading, sea passage & discharge, responsible person identified, language, additional VOC during washing

• Regulation applies to gas carriers for retention of non-methane VOCs

(Reg.15.7) but gas carriers not required to develop and implement a

VOC management plan

Schematic of a Vapour Emission

Control System

OIL

VAPOUR

H

MAST RISER

HIGH & LOW PRESSURE ALARMS

TANK LEVEL ALARMS

VAPOUR MANIFOLD

CARGO MANIFOLD

P/V VALVE

L

h hh

LEVEL GAUGE

MARPOL Annex VI

Regulation 16

Shipboard Incineration

Shipboard incineration - Regulation 16

• Incinerators to comply with MEPC.76 (40) & Appendix IV for ships

constructed/incinerator installed after 1 January 2000 (Reg. 16.6.1)

• Prohibits incineration of (Reg.16.2):

MARPOL Annex I, II & III cargoes, Polychlorinated biphenyls (PCB), garbage containing heavy metals, refined petroleum products

containing halogens, sewage and sludge oil not generated on board,

exhaust gas cleaning system residues

•Permits incineration of:

• PVC – plastics (where type approved to do so) (Reg.16.3)

• Sewage sludge and sludge oil permitted in boilers but not when in

ports, harbours and estuaries (Reg.16.)

•Incinerators installed before 24 May 2005 on domestic shipping can

be excluded by the Administration (Reg. 16.6.2)

•Operating manual, training, and temperature control (Reg. 16.7 –

16.9)

MARPOL Annex VI

Regulation 17

Reception Facilities

Reception Facilities – Regulation 17

• Parties obliged to provide facilities without causing delay for:

– Reception of ODS in ship repair yards (Reg.17.1.1)

– Reception of Exhaust Gas Cleaning System residues (Reg.17.1.2)

• Reception of ODS in ship breaking facilities (Reg.17.1.3)

• If unable to provide reception facilities then Party shall inform IMO (Reg.17.2 & 17.3)

Fuel Oil Availability – Regulation 18

• Parties to promote availability of compliant fuel oils and inform IMO (Reg.18.1)

• Ship found not to be in compliance (Reg.18.2.1)

– Record of actions taken to achieve compliance

– Need to demonstrate “best efforts” to obtain compliant fuel

• Ship should not be required to deviate or delay unduly the voyage in order to achieve compliance (Reg.18.2.2)

Fuel Oil Availability – Regulation 18

• Party required to take into account all relevant circumstances to determine action (Reg.18.2.3)

• Ship required to notify Administration and port of

destination when unable to purchase compliant fuel (Reg.18.2.4)

• Party to notify when ship presents evidence of

non-availability (Reg.18.2.5)

Fuel oil quality – Regulation 18

• Required properties of fuel oil identified (Reg.18.3)

• Excludes coal, nuclear and gas fuels from some of the provisions (Reg. 18.4)

• When receiving fuel oil ships of 400 gross tonnage and above are required to receive a

bunker delivery note (BDN) containing information in Appendix V (Reg. 18.5)

• BDN required to be retained for 3 three years and be available for inspection (Reg. 18.6)

Bunker Delivery Note - Regulation 18

• Bunker supplier must provide a Bunker Delivery Note (BDN)

• BDN to be retained for 3 years

• BDN to include:

– Name and IMO number of receiving ship

– Port and Date of commencement of delivery

– Name, address and telephone number of fuel supplier

– Product name and Quantity

– Density

– Sulphur content (actual)

– Declaration signed by supplier that the fuel oil conforms with Annex VI

Fuel oil quality – Regulation 18

• Inspection and verification by PSC

(Reg.18.7.1 & Reg.18.7.2)

• BDN accompanied by representative sample taken in accordance with

MEPC.96(47) which is retained under the

ship’s control for 12 months (Reg.18.8.1)

• Verification of bunker sample to be done in accordance with Appendix VI (Reg.18.8.2)

Fuel oil sample - Regulation 18

• Representative sample to be provided by the bunker supplier

• Sample to be sealed and signed by the supplier’s

representative and the master or officer in charge of the bunker operation

• Sample to be kept on board until the fuel oil is substantially consumed but in any case for not lessthan 1 year from time of delivery

• National Authorities to regulate suppliers to ensure their responsibilities for compliance

Local suppliers of fuel oil

• Parties are required to:

– maintain a register of local suppliers of fuel oil (Reg.18.9.1)

– require local suppliers of fuel oil to provide a certified BDN and sample (Reg.18.9.2), and retain a copy of the BDN for 3 years (Reg.18.9.3)

– take action against local suppliers of fuel oil (Reg.18.9.4)

– inform the Administration of a ship when the ship is found to be non-compliant (Reg.18.9.5)

– inform the IMO of all cases of non-compliant fuel oil being supplied (Reg.18.9.6)

Effects of Regulations 14 and 18

• Ship design changes

• Positive effect on fuel oil quality delivered to ships – ISO8217:2010

• Fuel cost?

• Additional operational requirements for crew

• Legal obligations on fuel suppliers

• Importance of commercial independent testing services

Summary - Regulation 18

• Not to exceed maximum permitted sulphur content

• Free from inorganic acid

• No added substance harmful to personnel, ship or machinery, or which contributes to additional air pollution

• Bunker delivery note, retained for 3 years

• Fuel oil sample, retained for 1 year

• Fuel Oil Availability

Port State Inspections – fuel oil

• Parties are required to:

– inform the Party or non-Party under whose jurisdiction the BDN was issued in cases of delivery of non-compliant fuel oil (Reg.10.1)

– ensure non-compliant fuel oil is brought into compliance (Reg.10.2)

• For ships on scheduled services with frequent and regular port calls Administration can provide alternative procedure to retaining on board BDN (Reg.11)

Enforcement – port State control

• Resolution MEPC.181(59) adopted 17 July 2009

• Identifies key compliance issues:

– Documentation - IAPP, EIAPP, BDN’s

– Compliance with SOx limits – fuel record book/EGS

– Compliance with engine limits for NOx

– Compliance with ODS provisions – ODS record book

– VOC management plan (if required)

– Type approval certificate for incinerator

Other relevant IMO Resolutions

• MEPC.180(59) – AMENDMENTS TO THE SURVEY GUIDELINES UNDER THE HARMONIZED SYSTEM OF SURVEY AND CERTIFICATION FOR THE REVISED

MARPOL ANNEX VI

• MEPC.182(59) – 2009 GUIDELINES FOR THE SAMPLING OF FUEL OIL FOR DETERMINATION OF COMPLIANCE WITH THE REVISED MARPOL ANNEX VI

• MEPC.183(59) – 2009 GUIDELINES FOR MONITORING THE WORLDWIDE AVERAGE SULPHUR CONTENT OF RESIDUAL FUEL OILS SUPPLIED FOR USE ON BOARD

SHIPS

• MEPC.184(59) – 2009 GUIDELINES FOR EXHAUST GAS CLEANING SYSTEMS

• MEPC.185(59) – GUIDELINES FOR THE DEVELOPMENT OF A VOC MANAGEMENT

PLAN

• MEPC.190(60) – NORTH AMERICAN EMISSION CONTROL AREA

Future developments• New part to MARPOL Annex VI to incorporate energy

efficiency measures

– Energy Efficiency Design Index (EEDI) new ships

– Ship Energy Efficiency Management Plan (SEEMP) all ships

• Monitoring of sulphur in fuel oil extended to include distillates i.e., fuels used in ECAs

• CG established by MEPC61 to consider how to establish a methodology to determine the availability of fuel oil to comply with the 0.5% standard by 2020

• Alternative fuels to achieve compliance e.g. LNG

Thank you for your attention

Any questions?

For more information please see: www.imo.org

marpolannex vi-imo

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