sox emission control areas (seca) - ppcac. · pdf filex emission control area – seca...

SOx Emission Control Areas (SECA)

Tony C.S.TeoSenior Principal Surveyor, DNV HoustonDecember 13th, 2006

Bunkering in the Baltic, North Sea & English Channel

Venue: Pacific Ports Air Quality Collaborative Conference

Version Slide 211 January 2007

AgendaMarpol 73/78 Annex VI

SECA requirements (Reg. 14)

Bunker Delivery Notes

Marpol Samples

Flag & Port State Enforcement

DNV Clean / Clean Design Notations

Considerations

Conclusion


PHILOSOPHY

“In the beginning we had to protect man

from the environment.

Today we have to protect the environment

from man”.

SECA


Ships’ air pollution in the world

Air pollution from ships represent only 1.8% of the global air pollution (GHG) from CO2

Ships carry more than 65% of all cargoes

Conclusion:

Transport using ships is very energy efficient


But….Ships’ SOx air pollution is high compared to other sources:

- SOx: 78% of total land based releases in 2001- NOx: 68% of total land based releases in 2001

Hence - International agreements:- IMO (MARPOL Annex VI)- EU regulations- Others: EPA (US)


Entry into Force- Ratifications status 15/50%- (Bahamas, Bangladesh, Barbados, Denmark,

Germany, Greece, Liberia, Marshall Islands, Norway, Panama, Singapore, Spain, Sweden, Vanuatu, Samoa)

- Enters into force

May 19th, 2005

MARPOL 73/78 Annex VI


Regulations:

- Reg. 12 - Ozone depleting substances - Reg. 13 - NOx engine emission requirement

- Reg. 14 - SOx

- Sulphur cap: 4.5%- SOx Emission Control Area – SECA (1.5%)- Alternative End-of-pipe treatment (6 g SOx/ kWh)

- Reg. 15 - Vapour control systems for tankers (USCG CFR 39)- Reg. 16 - Incinerators- Reg. 18 - Fuel Quality

MARPOL 73/78 Annex VI


Marpol Annex VI: 4.5% S, May 19th, 2005

SECA - Baltic Sea: 1.5% S, May 19th, 2006

SECA - N. Sea & English Channel: 1.5% S, Nov 19th, 2007

Applicable to all marine fuels for combustion engines, boilers, turbines

STATUS:

Average S content worldwide is about 2.7%

0.2% fuel tested by DNV > 4.5% S

4% fuel supplied < 1.5% S

Low S fuel demand:

14-20 million tons/yr worldwide

0.7 million tons/yr in NW Europe

SOx Emission Control Areas (SECA)


Operational requirements of Reg. 14

Must have 2 or 3 different fuel arrangements.

Implement a bunker strategy which includes:

- Evaluate if all combustion means can use LS FO

- How low sulphur fuel is obtained

- Time it takes to get below 1.5 % S cap (1 day or 2 days)

- Need to log when they change to and from Low Sulphur fuel

- May need more than one type of cylinder oil

Sox Emission Control Areas (SECA)

Fuel tank system configuration “Change-over”

To be completed upon SECA entry.

Fuel for combustion with S < 1.5%.

Upon completion of change-over the ship records:

- Volume LSFO per tank onboard

- Date + Time

- Ship’s position

DNV recommends using Engine Log , not Oil Record Book

F.O. quality now statutory requirement

No inorganic acid, chemical waste, within limits of SOx and NOx

Suppliers are Regulated and Accountable for quality

Port States: Obliged to:

- register suppliers

- investigate

- take action

- inform IMO on non-compliance

Regulation 18 - Fuel Oil Quality


Retention time onboard:- 3 years- available for inspection

MARPOL sample.

Retention time: 12 months in a safe location onboard.

Min: 400 ml, Intertanko: 750 ml

Recorded in Sample Inventory Log

Bunker Delivery Note (BDN).

Bunker Delivery Note

BDN

• statutory certificate for the fuel delivered

• not a commercial document

Bunker Delivery Note (BDN)

Content:Ship name and IMO no

Bunker port and date

Supplier name, address and phone no

Product name and quantity (MetricTon)

Density @ 15oC (kg/m3)

Sulphur content (% m/m) as per ISO 8754. (must be exact)

Declaration:

“It is certified that the fuel supplied is in conformity with regulation 14(1) or 4(a) and regulation 18(1) of MARPOL Annex VI”

Supplier’s Rep. Signature


Marpol Sample

Supplier’s Responsibility


Label

1. Location and Method sample was drawn

2. Date of commencement of delivery

3. Name of bunker vessel or installation

4. Name and IMO no. of receiving ship

5. Names and Signatures of Supplier’s and Ship’s reps.

6. Details of seal identification

7. Bunker grade

The MARPOL sample


Marpol Sample

WHERE:

At receiving ship’s F.O. manifold

HOW:

Continuously drawn during bunkering

Continuous-drip or auto sampling

Supplier’s Responsibility

Port & Flag State Enforcement

PSC


Flag & Port State scope:

- Is crew familiar with and have completed “change-over” prior to SECA entry - i.e. log.book, procedures

- Is crew familiar with requirements related to:


Marpol sampling procedure

Marpol sample

Flag & Port State Enforcement


“Detainable deficiencies”:

- Sulphur > 4.5% outside SECA

- Sulphur > 1.5% in SECA

- Crew unfamiliar with Marpol bunkering procedures,

BDN, Marpol sample

- Crew unfamiliar with LSFO “change-over” procedures

Enforcement - Port & Flag State Control


If BDN or Sample provided are not in compliance,

The master should document this with:

Notification to Flag Administration with copy to the Port State

Retain copy onboard together with Supplier’s Documents

Master’s Responsibility


Example

PROTEST NOTIFICATION


Alternative Solution

Sea Water

Exhaust Gases

Scrubbed gas re-heat section

Intimate mixing of exhaustgas and sea water

S.W. InletS.W. to cyclone separator& heat exchanger

Scrubbed & re-heated exhaust gases

Separation and Filtration Plant

Overboard Discharge of cleanedwater

Sludge ashore to authorisedcontractor

Exhaust Gas Cleaning System

(6 g SOx/ kWh)


Alternative SolutionExhaust Gas Cleaning Systems - emission criteria: 6g SOx/kWh

Prohibitions:

- Ports restriction for Scrubber discharge

- Discharge has Blue Sheen

- Filtration and treatment is necessary

- High exhaust gas flow – a technological challenge

- Restriction of Engine Room space

- Corrosion

- Reluctance by EU on acceptance

Sox Emission Control Areas (SECA)


Garbage:Sorting and managing

Ballast water:Treated or exchanged

DNV Environmental Class Notations

NOx:CLEAN: NOx-curveCLEAN DESIGN: US EPA

SOx:3 % S worldwide0.5 and 1.5 % in SECA and harbour0.2 % at berth in EU

VOCCargo vapour control

CLEAN DESIGN:Bilge 5 ppm oil

Sewage:Treatment/Holding tank

Emergency Response:Reduced Risk of SpillCLEAN DESIGN:Double hull for F.O.Tanks

CLEAN DESIGN:Collision Risk, Navigational aids &redundant propulsion

Recycling: Green Passport

Responsibility:Designated officer

Refrigerants:Global warming

CLEAN / CLEAN DESIGN: Lower Emissions / Accidental Discharges and Emissions


DNV Environmental Class Notations

370 vessels with CLEAN

CLEAN DESIGN

Cruise/passengers

Tanker

Supply/offshore

CLEAN

General cargo /container

RoRo/Car carrier

Passenger/ferriesLPG/LNG

Tanker

Supply/offshore

Other

CLEAN = Air Emissions & Sea Discharges

CLEAN DESIGN = CLEAN + Construction and Design

40 vessels with370 vessels with


• Calcium compound additive in higher based LO may overdose combustion chamber causing calcium build up on rings and cause liner scuffing when using LSFO. Need to use lower based L.O.

• S is a lubricity of FO – may cause fuel pump problems if < 0.05%.

• During “change over”, LSFO may cause gassing and thermal shock in fuel pumps in changing rapidly from heated to non heated fuel.

• Fuel pumps generally operate efficiently with 12 to 18 cSt FO. Distillate fuel has viscosity < 2 cSt. Potential leakage in fuel pump => reduced pressure & ignition delays.

• Concerns on compatibility of gasket material with MGO or diesel with reduced aromatisation.

• Boilers – normally designed to work on HFO.

Considerations:


Conclusion

“In the beginning we had to protect man

from the environment.

Today we have to protect the environment

from man”.

SECA


Objective: Safeguarding Life, Property and the Environment

Established: 1864

Today: 300 offices in 100 countries with 6000 employees