“Clearing the Air on Emissions” - Seaboard Marine · PDF fileIMO ≈ Tier 1 6.8 (7.2 NOx+HC) ... • Intended to make voluntary MARPOL Annex VI NOx limits mandatory for vessels

“Clearing the Air on Emissions”

Topics Covered

• Emissions overviewMARPOL Annex VI (IMO)EPA Marine Tier 1EPA Marine Tier 2 CommercialEPA Marine Tier 2 Recreational

• Additional Information

Emissions Overview

• Commercial marine engines are a source of air pollutants• These emissions occur in concentrated areas: in ports, along coast lines, along rivers • These are places with large populations that often have serious air pollution problems

Aircraft2.2%Nonroad SI

8.9%Recreational Marine

3.7%

Commercial Marine5.9%

Nonroad CI18.7%

Locomotive5.4%

HDDV10.0%

HDGV2.7%LDT

15.2%

LDV27.3%

Distribution of 2005 Mobile Source NOx+HC Emissions

Emissions Overview

• Marine diesel engine emissions contain:• Oxides of Nitrogen (NOx)

• Important part of urban haze• Causes smog and acid rain

• Diesel Particulate Matter (PM)• Affects Breathing and respiratory symptoms and can

cause increased respiratory disease and lung damage

• Carbon Monoxide (CO)• Reduces the delivery of oxygen to the body’s organs

• Hydrocarbons (HC)• Together with NOx and CO, one of the major causes of

ground-level ozone

Emissions Overview

• Worldwide regulations for Marine Diesel Emissions:

• United States• Annex VI to Marpol (73/78) or IMO• EPA Marine Tier 1 & 2

• Canada• Annex VI to Marpol (73/78) or IMO

• Europe• Annex VI to Marpol (73/78) or IMO (worldwide)• CCNR (Rhine River; Switzerland, Germany

Holland, Belgium and France)• Bodensee (Lake Constance; Switzerland,

Germany and Austria)

Emissions Overview

• Cummins is an industry leader in diesel engine design and manufacture and is working closely with regulatory organizations on current and future industry emissions requirements.

• We are proud of our track record in producing emissions certified product:• First manufacturer to receive IMO statement of compliance from

EPA (K19)• First manufacturer to receive EPA Tier 2 certification from EPA

(QSM11 2/11/03)

• All new Cummins Marine and Cummins Mercruiser Diesel products are and will be developed to meet future emissions requirements.

MARPOL Annex VI (IMO)

Marpol Annex VI

• Annex VI to the International Convention for the Prevention of Pollution from Ships (MARPOL 73/78) contains several air pollution requirements for marine vessels - Regulation 13 – Nitrogen Oxides (NOx)

• Regulatory Agency• International Maritime Organization (IMO) UN

• Certifying Agency• EPA (US)• Lloyd’s Register (rest of the world)

• Enforced by • (Probable) - US Coast Guard (US) • All countries are responsible for their own

enforcement

Marpol Annex VI

• The Regulation 13 engine emission limits are only for NOx• Limits apply to engines at or above 130 kW and are based on a NOx curve that is a function of rated engine speed.

• Applicable to• Engines installed on vessels constructed on or after 1 January 2000• Engines that undergo a major conversion on or after 1 January 2000

50 250 500 750 1000 1250 1500 1750 2000

Rated Engine Speed ("n")

9101112131415161718

g/kW

-hr N

Ox

Maximum Allowable NOx EmissionsFor Marine Diesel Engines

(Regulation 13 NOx Curve)

Commercial Marine Emissions Regulation Schedule

2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 U.S. EPA - Commercial (Final rule published 12/29/99 (Tier2) and 2/28/2003 (Tier 1). Cycles: E3, E2, D2, or C1.) Marine Products L/cyl

Emission Levels

3.9 L Prop / Aux 0.9-1.1 5.9 L Prop / Aux

≈ 6.8 (7.2 NOx+HC) / 5.0 / 0.30

8.3 L Prop / Aux 1.2-1.4 IMO ≈ 6.8 (7.2 NOx+HC) / 5.0 / 0.20 8.9 L Prop 1.5-1.9 11 L Prop / Aux

IMO ≈ 6.8 (7.2 NOx+HC) / 5.0 / 0.20

19 L Prop / Aux 2.5-4.9 38 L Prop / Aux 50 L Prop / Aux 60 L Prop / Aux

IMO Tier 1 ≈ 6.8 (7.2 NOx+HC) / 5.0 / 0.20

IMO – Commercial and Recreational (Applies to engines installed in boats built on or after 1/1/2000, and to major conversions. EPA Tier 1 (Applies to engines installed in vessels flagged in the U.S.) EPA Tier 2 (Applies to engines installed in vessels flagged in the U.S.) NOTES 1. IMO Tier 1 Tier 2

2. All requirements are effective for engines built on or after 1 January of the respective year except for IMO as noted above. 3. All standards are based upon ISO 8178 test cycles. E3 is to be used for variable-speed propulsion engines, E2 for constant-speed

propulsion engines, D2 for constant-speed auxiliary engines, and C1 for variable-speed auxiliary engines. 4. EPA Tier 2 includes combined NOx+HC limits instead of separate limits. Approximate NOx-only equivalents are provided for

comparison. 5. EPA Tier 2 includes “Not-to-Exceed” (NTE) limits, for each pollutant, that will go into effect beginning in 2007. Emissions at any point

within defined operating zones must be below 1.2 times the standard above 45% power, and 1.5 times the standard from 25-45% power.

6. IMO & Tier 1 NOx limits are a function of rated speed ‘n’ (rpm). For n > 2000, the NOx limit is 9.8 g/kW-hr. For n < 130, the limit is 17.0 g/kW-hr. For 130 < n < 2000, the limit is 45(n-0.2) g/kW-hr. Calculated NOx limits for selected speeds: 2000 rpm: 9.8 g/kW-hr, 1800: 10.0, 1600: 10.3, 1200: 10.9.

7. NOx / HC / CO / PM (g/kW-hr) [Conversion: (g/kW-hr) x 0.7457 = g/bhp-hr]

Marpol Annex VI

• IMO (Annex VI) has been ratified

• Regulation is enforceable on 20 May 2005 and may be retroactive for vessels built after January 1, 2000.

Marpol Annex VI

• What does the ratification of this regulation mean to me?• Since “IMO” engines have shipped with

technical files which include statements of compliance from the EPA and Lloyd’s Register, CMC/CMD customers are fully prepared for the ratification of MarpolAnnex VI.

Marpol Annex VI

• Compliance:• Technical File –

Statement of Compliance

• Label

Customers will need to:Keep Tech File onboard vesselKeep maintenance and service records (which impact emission characteristics)

• US EPA Marine Tier 1• 40 CFR 94 Dated 2/28/2003

EPA Marine Tier 1

• Identical NOx limits to those in the MARPOL Annex VI.

• Intended to make voluntary MARPOL Annex VI NOx limits mandatory for vessels flagged in the US.

• based on a NOx curve that is a function of rated engine speed.

50 250 500 750 1000 1250 1500 1750 2000

Rated Engine Speed ("n")

9101112131415161718

g/kW

-hr N

Ox

Maximum Allowable NOx EmissionsFor Marine Diesel Engines

(Regulation 13 NOx Curve)

EPA Marine Tier 1

• EPA Tier 1 Regulation applies to new commercial engines ≥ 2.5 liters/cylinder (HHP) installed on vessels flagged in the United States• Certifying Agency – US EPA• Enforced by – US Coast Guard (proposed)

• Implementation date is January 1, 2004 (based on engine build date)



Emission Levels


≈ 6.8 (7.2 NOx+HC) / 5.0 / 0.30


IMO ≈ 6.8 (7.2 NOx+HC) / 5.0 / 0.20


IMO Tier 1 ≈ 6.8 (7.2 NOx+HC) / 5.0 / 0.20








US EPA Marine Tier 2 • Commercial• 40 CFR 94 Dated 12/29/1999

EPA Marine Tier 2

• US EPA Tier 2 regulates NOx & HC, CO and PM

• Implementation dates based upon per cylinder displacement• HHP product Jan. 01, 2007• Mid-range and HD commercial product Jan. 01, 2004• Commercial Sterndrive product Jan. 01, 2005

• Applicable to engines manufactured on or after implementation date

• Applies to vessels flagged or documented in the U.S.• Certifying Agency – US EPA• Enforced by – US Coast Guard (proposed)



Emission Levels


≈ 6.8 (7.2 NOx+HC) / 5.0 / 0.30


IMO ≈ 6.8 (7.2 NOx+HC) / 5.0 / 0.20


IMO Tier 1 ≈ 6.8 (7.2 NOx+HC) / 5.0 / 0.20








EPA Marine Tier 2 – Customer Impact

• New Vessels (US Flagged) require new Certified Engines

• Starting with implementation dates of the regulation, a vessel is considered new until their equitable or legal title has been transferred to an ultimate purchaser.

• also consider a vessel new if it undergoes modifications such that the value of the modifications exceeds 50% of the value of the modified vessel.

• (assessed value after mod)-(assessed value before mod) > 0.5 (assessed value after mod)

EPA Marine Tier 2 – Customer Impact

• Repowers• Replacement engine must meet the

requirements applicable at time of its manufacture.

• Replacement engine must be equivalent (from an emissions standpoint) to the one being replaced.

EPA Marine Tier 2 – Decision Tree

New Vessel Used Vessel

Value ofmodificationsexceed 50% of

value of modifiedvessel?

1) New EPA Marine Tier 2 certifiedengine

or2) New IMO/Tier 1 certified engine

from inventory manufactured beforeEPA implementation date (See

Emissions Regulation Schedule).

Used, Rebuilt orRecon enginemay be used(must be an

emissionequivalent toengine being

replaced)

New Engine

Yes

No

EPA Marine Tier 1 & Tier 2

Compliance:• Technical File• Label

• Constant-speed Aux• ex. generator-drive

• Variable-speed Aux• ex. pump-drive

• Constant-speed Prop• ex. variable-pitch

propellers• Variable-speed Prop

• ex. fixed-pitched propellers

• Recreational

Customer Requirements:• Keep maintenance and

service records (for emission related service events)• Distributor invoices may

need to be more descriptive.

EPA Marine Tier 1 & Tier 2

• A person failing to comply with these regulations is subject to penalties of up to $25,000 per day per violation up to a maximum fine of $200,000.

US EPA Marine Tier 2 • Recreational• 40 CFR 94 Dated 11/08/02

EPA Marine Tier 2 - Recreational

• Recreational & Commercial emission level requirements are identical

• Implementation dates based upon per cylinder displacement• Recreational Sterndrive product Jan. 01, 2007• Recreational Midrange/HD product Jan. 01, 2006

• From Jan. 01, 2004 each recreational marine engine will be labeled “THIS ENGINE IS CATEGORIZED AS A RECREATIONAL MARINE ENGINE UNDER 40 CFR PART 94. INSTALLATION OF THIS ENGINE IN ANY NONRECREATIONAL VESSEL IS A VIOLATION OF FEDERAL LAW SUBJECT TO CIVIL PENALTY”

EPA Marine Tier 2 - Recreational

• The EPA defines a “recreational vessel” as a vessel intended by the vessel manufacturer to be operated primarily for pleasure or leased, rented or chartered to another for the latter’s pleasure. Which includes:• Charter fishing vessels < 100 gross tons that carry

not more than 6 paying customers.

Recreational Marine Emissions Regulation Schedule 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 U.S. EPA – Recreational (Final rule published 11/8/2002 (Tier2) Cummins Products L/cyl

Emission Levels

1.7 L Sterndrive 0.4 – 0.7 2.8 L Sterndrive

7.5 NOx+HC / 5.0 / 0.40

4.2 L Sterndrive 0.7 IMO 7.5 NOx+HC / 5.0 / 0.40 3.9 L Propulsion 0.9-1.1 5.9 L Propulsion

IMO ≈ 6.8 (7.2 NOx+HC) / 5.0 / 0.30

8.3 L Propulsion 1.2-1.5 8.9 L Propulsion

IMO ≈ 6.8 (7.2 NOx+HC) / 5.0 / 0.20

11 L Propulsion 1.6-1.9 IMO ≈ 6.8 (7.2 NOx+HC) / 5.0 / 0.20

IMO – Commercial and Recreational (Applies to engines installed in boats built on or after 1/1/2000, and to major conversions. EPA Tier 2 (Applies to engines installed in vessels flagged in the U.S.) NOTES 1. IMO Tier 2




within defined operating zones must be below 1.2 times the standard above 45% power, and 1.5 times the standard from 25-45% power. 6. IMO NOx limits are a function of rated speed ‘n’ (rpm). For n > 2000, the NOx limit is 9.8 g/kW-hr. For n < 130, the limit is 17.0 g/kW-hr.

For 130 < n < 2000, the limit is 45(n-0.2) g/kW-hr. Calculated NOx limits for selected speeds: 2000 rpm: 9.8 g/kW-hr, 1800: 10.0, 1600: 10.3, 1200: 10.9.


Additional Information – Regulation Summary

Regulation MARPOL Annex VI EPA Tier 1 EPA Tier 2 Applicability Diesel Marine engines (propulsion &

auxiliary), for both commercial and recreational use, whether new or

undergoing major conversion, with power > 130 kW (> 175 HP).

Emergency Standby engines are excluded.

Diesel Marine Engines (propulsion & auxiliary) for

commercial use with per cylinder displacement ≥ 2.5

liters/cylinder.

Diesel Marine Engines (propulsion & auxiliary) for commercial and recreational

use with power > 37 kW (50 HP)

Region All waters except where local Administration has an alternative NOx

control measure, or where local Administration excludes vessels

operated solely in domestic waters.

Vessels flagged or documented in the United

States.

Vessels flagged or documented in the United

States.

Regulates NOx NOx NOx & HC, CO, PM

Limits Based On Function of rated speed Function of rated speed Based on per cylinder displacement and application

Implementation Date

Once ratified, retroactively enforceable to January 1, 2000 (Keel-laid date)

For commercial engines with per cylinder

displacement≥2.5 liters / cylinder January 1, 2004.

(engine build date)

MR/HD commercial engines - January 1, 2004.

Engines with displacement of ≥2.5 liters / cylinder (HHP),

January 1, 2007 (engine build date)

Compliance Technical File Dataplate / Label Dataplate / Label

• EPA’s website contains all of these regulations as well as fact sheets(www.epa.gov/otaq/marine.htm)

http://www.epa.gov/otaq/marine.htm

Documents

“Clearing the Air on Emissions” - Seaboard Marine · PDF fileIMO ≈ Tier 1 6.8 (7.2 NOx+HC) ... • Intended to make voluntary MARPOL Annex VI NOx limits mandatory for vessels