MARPOL Annex VI: Air Pollution Prevention

AIR POLLUTION PREVENTIONAIR POLLUTION PREVENTION

Revisions of Marpol Annex VI Revisions of Marpol Annex VI

November 2009November 2009

AIR POLLUTION PREVENTION AIR POLLUTION PREVENTION

1. IMO and Regional Ship Air Emission Developments1. IMO and Regional Ship Air Emission Developments

• • Air pollution protection: commenced in the late 1980’sAir pollution protection: commenced in the late 1980’s IMO decided to include the issue of air pollutionIMO decided to include the issue of air pollution in environmental programme in environmental programme iin 1988n 1988

• • Resolution A.719 (17) adopted in 1991Resolution A.719 (17) adopted in 1991 establishing a policy on the prevention of air pollutionestablishing a policy on the prevention of air pollution from shipsfrom ships (adoption of Annex VI to MARPOL 73/78)(adoption of Annex VI to MARPOL 73/78)

• • IMO Air Pollution Conference in September 1997IMO Air Pollution Conference in September 1997 Protocol of 1997 to amend MARPOL 73/78 Protocol of 1997 to amend MARPOL 73/78 and and to includeto include RegulationsRegulations for the Prevention of Air Pollution from Shipsfor the Prevention of Air Pollution from Ships Greenhouse Gas Emissions not includedGreenhouse Gas Emissions not included, , butbut ConfConferenceerence Res.7 and 8 dealt with PFC’s and CO2 emissions respectivelyRes.7 and 8 dealt with PFC’s and CO2 emissions respectively

• • Annex VI entered into force in 2005Annex VI entered into force in 2005

AIR POLLUTION PREVENTION AIR POLLUTION PREVENTION

1. IMO and Regional Ship Air Emission Developments (cont.)1. IMO and Regional Ship Air Emission Developments (cont.)

• • Baltic Sea – SECA from May 2006Baltic Sea – SECA from May 2006 • • North Sea/English Channel– SECA from Nov 2007North Sea/English Channel– SECA from Nov 2007• • Major Revision of Major Revision of MARPOL Annex VI completedMARPOL Annex VI completed in in Oct 2008 Oct 2008• • Revised Annex VI effective from 1 July 2010Revised Annex VI effective from 1 July 2010• • European Sulphur Directive governing emissions in portEuropean Sulphur Directive governing emissions in port (0.1% S at berth 1 Jan 2010)(0.1% S at berth 1 Jan 2010)• • Port regulations in California (USA), Vancouver (Canada) for ship berthingPort regulations in California (USA), Vancouver (Canada) for ship berthing The California Air Resources Board (CARB) adopted the Regulations to reduce emissionsThe California Air Resources Board (CARB) adopted the Regulations to reduce emissions from auxiliary diesel engines and diesel - electric engines operated on ocean-goingfrom auxiliary diesel engines and diesel - electric engines operated on ocean-going vessels vessels within California waters and 24 nautical miles off the California baseline.within California waters and 24 nautical miles off the California baseline. Click Click here

• • ISO ongoingISO ongoing work on Marine Fuel Oil specificationswork on Marine Fuel Oil specifications• • Discussion and development : of on-shore power supply - also called Discussion and development : of on-shore power supply - also called Alternative Marine Power (AMP) or Cold-ironingAlternative Marine Power (AMP) or Cold-ironing•• Green House Gases (GHG) limitationsGreen House Gases (GHG) limitations

AIR POLLUTION PREVENTIONAIR POLLUTION PREVENTION

2. Key Amendments to MARPOL Annex VI cont.2. Key Amendments to MARPOL Annex VI cont.

• • Reg. 13 Progressive reductions in nitrogen oxide (NOx) emissions Reg. 13 Progressive reductions in nitrogen oxide (NOx) emissions

• • Establishment of Emission Control Areas (ECAs) formerly only SECAsEstablishment of Emission Control Areas (ECAs) formerly only SECAs::

““Emission Control Area” is an area where the adoption of special mandatoryEmission Control Area” is an area where the adoption of special mandatory measures for measures for

emissions from ships is required to prevent, reduce and control air pollution from SOx, NOx emissions from ships is required to prevent, reduce and control air pollution from SOx, NOx

and particulate matter. Areas listed in Regulations 13 and 14.and particulate matter. Areas listed in Regulations 13 and 14. ””

• • Revised NOx-CodeRevised NOx-Code

• • Reg. 14 Reduced SOx-emission limitsReg. 14 Reduced SOx-emission limits

• • Reg. 4 Expanded scope for equivalent measuresReg. 4 Expanded scope for equivalent measures

• • Clarified criteria for verifying compliant fuelClarified criteria for verifying compliant fuel

•• Reg. 15 Improved control on VOC-emissionsReg. 15 Improved control on VOC-emissions

• • Reg. 18 New provision for Fuel Oil unavailabilityReg. 18 New provision for Fuel Oil unavailability

• • Revised guidance for Exhaust Gas Revised guidance for Exhaust Gas Cleaning Systems Cleaning Systems

AIRAIR POLLUTION PREVENTION POLLUTION PREVENTION

NOx limitsNOx limits RequirementsRequirements Effective forEffective for

TIER I SSE = 17.0 g/kWh MSE = 45 x RPM(-0.2) g/kWh)HSE = 9.8 g/kWh

Ships built: 01 Jan 2000 to 01 Jan 2011 (the standards in force)

TIER II SSE = 4.4 g/kWhMSE = 44 x RPM(-0.23) g/kWh)HSE = 7.7 g/kWh

Ships built after 01 Jan 2011

TIER III SSE = 3.4 g/kWhMSE = 9 x RPM(-0.2) g/kWhHSE = 2.0 g/kWh

Ships built after 01 Jan 2016 and operating in ECAs

3. Revised Marpol Annex VI 3. Revised Marpol Annex VI

3.1. 3.1. Regulation 13 - NOx emission and NOx Technical CodeRegulation 13 - NOx emission and NOx Technical Code

NEW EXHAUST EMISSION NOx LEGISLATIONNEW EXHAUST EMISSION NOx LEGISLATION

.

SSE -Slow Speed Engines MSE - Medium Speed Engines HSE - High Speed Engines


3.1. NOx emission3.1. NOx emission, , Technical Code cont.Technical Code cont.

Remarks: Remarks:

1.1. Tier III limits Tier III limits - - applicable to engines of power applicable to engines of power

output > 750 kW exclusively in ECAs.output > 750 kW exclusively in ECAs.

2. 2. IMO Review in 2012/13 planIMO Review in 2012/13 planningning to verify to verify

technological development to implement Tier III standard.technological development to implement Tier III standard.

3. In order to meet NOx limits - exhaust gas cleaning system 3. In order to meet NOx limits - exhaust gas cleaning system

can be applied.can be applied.

4. 4. RRevised evised NOx Technical Code 2008 ((entering entering into force on into force on

0101July July 2010) 2010) toto be u be usedsed in the certification, testing, and in the certification, testing, and

measurement procedures.measurement procedures.


3.1.1. 3.1.1. New measures on engines of ships built: New measures on engines of ships built: Jan Jan 1990 – 1990 – Dec Dec 19991999 The NOx emissions at Tier I level upgraded for engines of power The NOx emissions at Tier I level upgraded for engines of power output > 5,000 kW and per cylinder displacement at or > 90 litresoutput > 5,000 kW and per cylinder displacement at or > 90 litres

The upgrading is provided with approved and cost effective The upgrading is provided with approved and cost effective method for NOx method for NOx limitation andlimitation and should not: should not:

• reduce the engine rating by more than 1% reduce the engine rating by more than 1% • increase the fuel consumption by more than 2%, and increase the fuel consumption by more than 2%, and • have have negativenegative effect on the engine durability or reliability effect on the engine durability or reliability

For For Engines NOT complying with Tier I NOx emission limitations:Engines NOT complying with Tier I NOx emission limitations:

• • measures against ship only if there is a certified, efficientmeasures against ship only if there is a certified, efficient commerciallycommercially

available systemavailable system

•• rules for certification, verification and documentation of scrubbers rules for certification, verification and documentation of scrubbers

and and upgrade at the ship’s first Renewal Survey if there is an approvedupgrade at the ship’s first Renewal Survey if there is an approved

method for upgrading at least to Tier I standardmethod for upgrading at least to Tier I standard

• • if system not available, the next Annual Survey after that method is availableif system not available, the next Annual Survey after that method is available


3.2. Regulation 14 - SOx & Particulate Matter 3.2. Regulation 14 - SOx & Particulate Matter emission limitsemission limits

Sulphur Content of Fuel Oil LimitsSulphur Content of Fuel Oil Limits

Note: Sulphur content documented by supplier as required by RegulationNote: Sulphur content documented by supplier as required by Regulation 1818

** Review of 0.50% standard to be Review of 0.50% standard to be carried outcarried out by experts by by experts by 2018 2018 to determine availability of such fuel. to determine availability of such fuel.

If not possible, then If not possible, then the final the final date date isis Jan 1, 2025Jan 1, 2025))

* * * * From From 1 Jan 2010 1 Jan 2010 in EU ports at berth and inland waters (EU Directive 99/32 Amendment)in EU ports at berth and inland waters (EU Directive 99/32 Amendment)

AreaArea Sulphur contentSulphur content // Effective forEffective for

Open Sea (Global)Open Sea (Global) 4.50%4.50% Prior to Prior to 1 1 Jan 2012 Jan 20123.50%3.50% 1 1 JanJan 201220120.50%*0.50%* 11Jan Jan 20202020

SOx/PM Emission Control SOx/PM Emission Control AreasAreas

1.50%1.50% Prior to Prior to 1 1 MarMar 201020101.00%1.00% 1 1 JanJan 2012 20120.10%0.10% 1 1 JanJan 2015** 2015**

AIRAIR POLLUTION PREVENTION POLLUTION PREVENTION3.3 Fuel changeover to be recorded:3.3 Fuel changeover to be recorded:

Ships using separate fuel oils entering or leaving an ECA shall:Ships using separate fuel oils entering or leaving an ECA shall:

• • possess a written procedure indicating proper fuel oil change-over, providing possess a written procedure indicating proper fuel oil change-over, providing fuel oil system flushing of all fuel oils exceeding the permissible sulphur fuel oil system flushing of all fuel oils exceeding the permissible sulphur

content prior to entry into an ECA.content prior to entry into an ECA.

• • ensure that there is written record ( e.g. ER log book) of the volume of low ensure that there is written record ( e.g. ER log book) of the volume of low sulphur fuel oils in each tank as well as the date, time, and position of the ship sulphur fuel oils in each tank as well as the date, time, and position of the ship when any fuel-oil-change-over operation is completed prior to the entry into an when any fuel-oil-change-over operation is completed prior to the entry into an ECA or commenced after exit from such an areaECA or commenced after exit from such an area

Note: During the first twelve months immediately following an amendment designatingNote: During the first twelve months immediately following an amendment designating a specific a specific

ECA ECA ,,ships operating in that Emission Control Area are exempt from the above Requirements.ships operating in that Emission Control Area are exempt from the above Requirements.

Click here for Div Tech Work Instruction ”Fuel Change over Information on Boilers Click here for Div Tech Work Instruction ”Fuel Change over Information on Boilers

and and Diesel Engines with respect to Low Sulphur Fuel useDiesel Engines with respect to Low Sulphur Fuel use.” .”


3.4. 3.4. Equivalent measures scope (Regulation 4)Equivalent measures scope (Regulation 4)

AAlternative technology (any fitting, material, appliance or apparatus to lternative technology (any fitting, material, appliance or apparatus to

be fitted in a ship or other procedures, alternative fuel oils, orbe fitted in a ship or other procedures, alternative fuel oils, or

compliance methods e.g. scrubbers)compliance methods e.g. scrubbers) can be acknowledged by can be acknowledged by

Administration as is an "equivalent measure” provided that:Administration as is an "equivalent measure” provided that:

• • equivalent efficiency in terms of SOx, PM and NOx emissions equivalent efficiency in terms of SOx, PM and NOx emissions

is ensuredis ensured

• • its operation is within the requirements of the IMO guidelinesits operation is within the requirements of the IMO guidelines

• • environment is not harmed (potential water discharge issue)environment is not harmed (potential water discharge issue)


3.5. Exhaust Gas Cleaning Systems3.5. Exhaust Gas Cleaning Systems

IMO Marine Environmental Protection Committee has adopted IMO Marine Environmental Protection Committee has adopted

Resolution MEPC.184(59): ”2009 GUIDELINES FOR EXHAUST GAS Resolution MEPC.184(59): ”2009 GUIDELINES FOR EXHAUST GAS

CLEANING SYSTEM” (click here) entering into force on 1 July 2010.CLEANING SYSTEM” (click here) entering into force on 1 July 2010.

Revised guidance for Exhaust Gas Cleaning Systems Revised guidance for Exhaust Gas Cleaning Systems

(EGCS Unit) (EGCS Unit) mainly deals with:mainly deals with:

• • rules for certification, verification and documentation of scrubbers rules for certification, verification and documentation of scrubbers

• • new regulations for Wash Water Dischargenew regulations for Wash Water Discharge (monitoring and recording) (monitoring and recording)


3.5.1. The requirements and documents for EGCS Units3.5.1. The requirements and documents for EGCS Units

1. The Guidelines permit 1. The Guidelines permit two schemes two schemes for EGCS Unit :for EGCS Unit :

• • Scheme A (Unit Certification with Parameter and Emission Checks)Scheme A (Unit Certification with Parameter and Emission Checks)

• • Scheme B (Continuous Emission Monitoring with Parameter Checks)Scheme B (Continuous Emission Monitoring with Parameter Checks)

2. SOx Emissions Compliance Plan (SECP) approved by the Administration.2. SOx Emissions Compliance Plan (SECP) approved by the Administration.

3. Technical Manual (ETM): nominal capacity, operating limits, maintenance3. Technical Manual (ETM): nominal capacity, operating limits, maintenance

/survey procedures /survey procedures

4. SECC SOx Emissions Compliance Certificate - testing, approval of ETM4. SECC SOx Emissions Compliance Certificate - testing, approval of ETM

5. EGC Record Book - Log book for scrubber maintenance5. EGC Record Book - Log book for scrubber maintenance

6. 6. Onboard Monitoring Manual (OMM) - monitoring specification, Onboard Monitoring Manual (OMM) - monitoring specification,

maintenancemaintenance and survey procedures, etc and survey procedures, etc ..


3.5.2. Benefits and main drawbacks of using scrubbers3.5.2. Benefits and main drawbacks of using scrubbers

Benefits:Benefits:

• • cost effectiveness - fuel price scenarios make scrubbers more attractivecost effectiveness - fuel price scenarios make scrubbers more attractive

• • developing technology - more stationary power plants with scrubbers.developing technology - more stationary power plants with scrubbers.

• • evident progress made in the revised guidelines by IMO - wash water evident progress made in the revised guidelines by IMO - wash water

• • regulations and certification proceduresregulations and certification procedures


Disadvantages of using scrubbers:Disadvantages of using scrubbers:

• • Relatively high cost of the scrubber system (comprising Relatively high cost of the scrubber system (comprising

testing and approval)testing and approval)

• • Energy – consuming processEnergy – consuming process

• • Acidity of wash water discharge affecting e.g. propeller, Acidity of wash water discharge affecting e.g. propeller,

rudder, antifouling system etc.rudder, antifouling system etc.

• • Space consuming unit in the engine room and in particular Space consuming unit in the engine room and in particular

the funnel. the funnel.

• • Problems with discharge of scrubber effluent overboard Problems with discharge of scrubber effluent overboard

in portsin ports within ECA and waste disposalwithin ECA and waste disposal

• • COCO2 2 emission emission


3.6. Fuel Oil Availability and Quality (Regulation 18) 3.6. Fuel Oil Availability and Quality (Regulation 18)

If a ship is found not to meet the standards for compliant fuel oils,If a ship is found not to meet the standards for compliant fuel oils,

the competent authority can require the ship to:the competent authority can require the ship to:

•• present a record of the actions taken to achieve compliance; andpresent a record of the actions taken to achieve compliance; and

•• provide evidence that it attempted to purchase compliant fuel oil andprovide evidence that it attempted to purchase compliant fuel oil and

consequently no measures taken against the shipconsequently no measures taken against the ship•• not to deviate from the voyage and not to be delayednot to deviate from the voyage and not to be delayed•• to notify its Administration and the relevant port of call each time it to notify its Administration and the relevant port of call each time it cannot find the compliant fuel.cannot find the compliant fuel.

For IMO Resolution For IMO Resolution MEPC.182(59)MEPC.182(59): „2009 GUIDELINES FOR THE SAMPLING OF FUEL OIL FOR : „2009 GUIDELINES FOR THE SAMPLING OF FUEL OIL FOR

DETERMINATION OF COMPLIANCE WITH THE REVISED MARPOL ANNEX VI: click hereDETERMINATION OF COMPLIANCE WITH THE REVISED MARPOL ANNEX VI: click here

This Resolution supersedes Res. MEPC.96(47) This Resolution supersedes Res. MEPC.96(47)


3.7. 3.7. Greenhouse GasGreenhouse Gas (GHG) Emissions from Ships(GHG) Emissions from Ships

• • according to IMO data - international shipping caused 2.7% according to IMO data - international shipping caused 2.7% of the global CO2 emissions in 2007 (machineryof the global CO2 emissions in 2007 (machinery exhaust gases)exhaust gases)..

Greenhouse gases were not significantly covered by IMO regulationsGreenhouse gases were not significantly covered by IMO regulations

until:until: 5 Dec 20035 Dec 2003,, when IMO adopted resolution A.963(23) when IMO adopted resolution A.963(23) IMO IMO

Policies and practices related to the reduction of greenhouse Policies and practices related to the reduction of greenhouse

gas emissions from shipsgas emissions from ships..

MEPC is to:MEPC is to:

• • identify and develop a work plan and timetable for GHG limitationsidentify and develop a work plan and timetable for GHG limitations

•• establish GHG emissions baseline guidelines for future applicationestablish GHG emissions baseline guidelines for future application

•• create CO2 indexing schemecreate CO2 indexing scheme

• • develop technical, operational and market-based reduction solutionsdevelop technical, operational and market-based reduction solutions


3.7.1. 3.7.1. IMO GHG Study - MEPC 59 OutcomeIMO GHG Study - MEPC 59 Outcome

In July 2009: MIn July 2009: MEPC EPC developed a package of GHG emissionsdeveloped a package of GHG emissions reduction reduction throughthrough technical/operational measures i.e.: technical/operational measures i.e.: 1.1. for new shipsfor new ships:: , , ”The Energy Efficiency Design Index” (EEDI)”The Energy Efficiency Design Index” (EEDI) (improving design and propulsion technologies)(improving design and propulsion technologies) 2.2. for all ships:for all ships: ””Ship Energy Efficiency Management Plan” (SEEMP) Ship Energy Efficiency Management Plan” (SEEMP) comprising best practices for the fuel efficient operation andcomprising best practices for the fuel efficient operation and ””Ship Energy Efficiency Operational Indicator” (SEEOI)Ship Energy Efficiency Operational Indicator” (SEEOI)

IIn addition - n addition - Market - Based Instruments (MBIMarket - Based Instruments (MBI) ) are to be introduced are to be introduced for two mainfor two main purposes: • off-setting growing ship emissions and purposes: • off-setting growing ship emissions and • • providing a fiscal incentive to operate ships in energy efficient wayproviding a fiscal incentive to operate ships in energy efficient way

Note: Work on all measures to be continued at forthcoming meetings of the MEPCNote: Work on all measures to be continued at forthcoming meetings of the MEPC,,

Considering Considering the outcome of Copenhagen UN Climate Change Conference (COP 15) in Dec 2009.the outcome of Copenhagen UN Climate Change Conference (COP 15) in Dec 2009.


3.8. 3.8. Volatile Organic Compounds (VOC’s) Regulation 15Volatile Organic Compounds (VOC’s) Regulation 15

• • tankers subjected to vapour emission control shall be provided tankers subjected to vapour emission control shall be provided

with an approved Vapour Collection System (VCS) to be operated with an approved Vapour Collection System (VCS) to be operated

during the loading of such cargoesduring the loading of such cargoes**. .

• • VCP VCP shall Comply with IMO Guidelines shall Comply with IMO Guidelines ((MSC/Circ.585MSC/Circ.585))

• • revisedrevised Annex VI to MARPOL requires crude oil tankers ≥Annex VI to MARPOL requires crude oil tankers ≥ 400 grt 400 grt

to implement and keep onboard an approved to implement and keep onboard an approved VOC Management Plan.VOC Management Plan.

((Effective as from 01Effective as from 01 July 2010) July 2010)

• • The plan is to be ship specific, taking into account The plan is to be ship specific, taking into account IMO GuidelinesIMO Guidelines****

* * for existing tankers not fitted with VCS systems, three years after respective terminal for existing tankers not fitted with VCS systems, three years after respective terminal

requirements becrequirements becoome effectiveme effective

**** Click here for ”Guidelines for the Development of VOC Management Plans” Click here for ”Guidelines for the Development of VOC Management Plans”


Volatile Organic Compounds (VOC’s) Volatile Organic Compounds (VOC’s) cont.cont.

VOC Management Plan shallVOC Management Plan shall::

• • Provide written procedures for minimizing VOC emissions during the loading Provide written procedures for minimizing VOC emissions during the loading

and sea passage.and sea passage.

• • Give consideration to the additional VOC generated during Crude Oil WashingGive consideration to the additional VOC generated during Crude Oil Washing

• • Identify a person responsible for implementing the plan.Identify a person responsible for implementing the plan.

• • Be written in the working onboaBe written in the working onboardrd language and, if language and, if it it is not English, French or is not English, French or

Spanish, include an appropriate translationSpanish, include an appropriate translation

Note: Regulation 15 shall also apply to gas carriers only if the type of loading and containment Note: Regulation 15 shall also apply to gas carriers only if the type of loading and containment

systems allow safe retention of non-methane VOCs on board or their safe return ashore.systems allow safe retention of non-methane VOCs on board or their safe return ashore.

Technology

MARPOL Annex VI: Air Pollution Prevention