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MARPOL, ANNEX VI
PREVENTION OF AIR POLLUTION FROM SHIPS
CONTENT
Protocol of 1997 to amend MARPOL 73/78
Annex: Annex VI to the International Convention for the Prevention of Pollution from Ships, 1973, as amended by the Protocol of 1978 relating thereto
Chapter I – General
Chapter II – Survey, certificate and means of control
Chapter III – Requirements for control of emissions from ships
Appendix I – Form of IAPP Certificate
Appendix II – Test cycles and weighing factors
Appendix III – Criteria and procedures for designation of SOx emission areas
Appendix IV – Type approval and operating limits for shipboard incinerators
Appendix V – Information to be included in the bunker delivery note
Resolutions of the 1997 MARPOL Conference
Resolution 1 – Review of the 1997 Protocol
Resolution 2 – Technical Code on Control of Emission of Nitrogen Oxides from Marine Diesel Engines
Resolution 3 – Review of nitrogen oxides emission limitations
Resolution 4 – Monitoring the world-wide average sulphur content of residual fuel oil supplied for use onboard ships
Resolution 5 – Considerations of measures to address sulphur deposition in north-west Europe
Resolution 6 – Introduction of the harmonized system of survey and certification in Annex VI
Resolution 7 – Restriction on the use o perfluocarbons on board ships
Resolution 8 – CO2 emission from ships
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MARPOL, ANNEX VI
PREVENTION OF AIR POLLUTION FROM SHIPS
Annex VI is intended to address the following topics:
- Ozone depleting substances (reg.VI/12),
- Nitrogen oxide (NOx) emissions from diesel engines (reg. VI/13),
- Sulphur dioxide (SOx) emissions from ships (reg.VI/14),
- Volatile organic compound (VOCs) emissions from cargo tanks of oil tankers, (reg.VI/15)
- Shipboard incineration of waste (reg.VI/16),
- Fuel oil quality (reg.VI/18).
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MARPOL, ANNEX VI
PREVENTION OF AIR POLLUTION FROM SHIPS
OZONE-DEPLETING SUBSTANCES (Reg.VI/13)
For the purpose of Annex VI, ozone-depleting substances are those listed in Annexes A, B, C or E of the Montreal Protocol on Substances that Deplete the Ozone Layer, 1987.
Substances which 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 Trichlorofluromethane
- 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 Cholopentafluoroethane
Reg.VI/13 provides for the following:
- Prohibition of release of ozone-depleting substances
- Prohibition of new installations containing ozone depleting substances on all ships (New installations of halon are already prohibited through the SOLAS Convention)
New installations containing hydrochlorofluocarbons (HCFCS) are authorized until 1 January 2020
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MARPOL, ANNEX VI
PREVENTION OF AIR POLLUTION FROM SHIPS
NITROGEN OXYDE (NOx) EMISSIONS (Reg.VI/13)
The Regulation VI/13, addressing Nitrogen Oxide (NOx) emissions is, in fact in force (or has a retroactive application)since 1 January 2000 as, as from this date all diesel engines of 130 kW output or more installed on ships constructed on/after 1 January 2000 to comply with the specified NOx limits.
The regulation also applies to diesel engines which have undergone and/or undergo a major conversion on/after 1 January 2000.
A major conversion of an engine means the modification of an engine where:
- An engine is replaced by a new engine built on/after 1 January 2000,
- An engine is subjected to a substantial modification as defined,
- The maximum continuous rating (output) of the engine is increase by more than 10%.
The major conversion clause may have significant involvement as it eventually extend the scope of control to engines which would not otherwise be concerned (installed on ships constructed before 1 January 2000). Any operational or technical modification made after 1 January 2000 (Change of fuel timing, fuel injection equipment…) could increase the defined level of NOx emissions. The owners would have to demonstrate that such operational or technical changes do not involve an unacceptable increase in emissions.
The NOx emission limits are related to engine rated crankshaft speed:
Rated engine speed (n) (rpm) / NOx emission limit (g/kWh)Less than 130 / 17.0
130 to 1999 / 45 X n-0.2
2000 and more / 9.8
NOx Technical Code
This is a mandatory Code developed by the IMO in line with the Annex VI. The NOx Technical Code defines how the NOx limitation shall be done. It also provides for definitions such as “substantial modification” of an engine and the level of NOx emissions.
Emergency diesel engines and diesel engines installed in lifeboats are not subjected to this regulation.
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MARPOL, ANNEX VI
PREVENTION OF AIR POLLUTION FROM SHIPS
SULPHUR OXIDE (SOx) EMISSIONS (Reg.VI/14)
Maximum limit
The sulphur content of any fuel oil used on board shall not exceed 4.5% m/m. This limit stands, irrespective of the fuel grade or the type of combustion machinery in which the fuel are to be used.
The Netherlands have managed a sulphur monitoring program since 1999 and reported to the MEPC. It does appear that the delivery of fuel oil with a sulphur content exceeding 4.5% m/m to ships is less than 1% each year. The overall average sulphur value is 2.6-2.7 m/m. As far as the year 2003 is concerned (MEPC.52/4/8), 90% of the deliveries had a sulphur content from 1.5% to 4.00%, 50% of the deliveries had a sulphur content of 2-3% and 1% of the deliveries had a sulphur content over 4% (5 samples were however found over 5.00%).
The limit of 4.5% does not appear to involve a significant restriction on current fuel supplies.
SOx Emission Control Areas
A lower limit is placed in special areas, SOx emission control areaswhere the sulphur content shall not exceed 1.5% m/m. An other accepted option is to limit the maximum SOx content of the exhaust gas to 6.0 g/kWh throughan exhaust gas cleaning system.
It is expected that the majority of ships will comply with the SOx Emission Control Areas requirements by limiting the fuel oil content by the use of low sulphur residual fuel or gas oils. It will be necessary to ensure that ships entering the area have both the segregate bunker capacity and the means to change over from the heavier sulphur fuel to the lower sulphur fuel before they enter the SOx Emission Control Area.
The Baltic Sea (as defined in MARPOL Annex I) is already a SOx Emission Control Area.
Depending on the running of tacit amendment procedure, the North Sea and the French Channel will be the next SOx Emission Control Area some time in 2007 (At this stage, there is regrettably no information with regard to the English Channel). Other areas, such as the West of the Europ, theUS coastal waters and the Mediterranean Sea, are likely to be proposed as SOx Emission Control Areas.
Appendix III to the Annex provides for the criteria and procedures for designation of SOx emission control areas.
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MARPOL, ANNEX VI
PREVENTION OF AIR POLLUTION FROM SHIPS
VOLATLE ORGANIC COMPOUND (VOCs) (Reg.VI/15)
A Party may designate ports or terminal under its jurisdiction as areas in which the emissions of volatile organic compounds from cargo tanks of oil tankers are controlled. The Party shall advise the IMO and the notification shall include information of the size of the tankers to be controlled and on cargoes requiring vapour emission control systems. The Party shall ensure that vapour emission control system are operated safely and so as to avoid any delay to the ship.
The tankers subjected to vapour emission control in such ports and terminals shall be equipped with a vapour emission control system approved by the administration taking into account the standard developed by the IMO.
Associated Document:
Circular Msc/Circ.585 Standard for Vapour Emission Control System.
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MARPOL, ANNEX VI
PREVENTION OF AIR POLLUTION FROM SHIPS
SHIPBOARD INCINERATION (Reg.VI/16)
Shipboard incinerators
Incinerators installed on board a ship as from 1 January 2000 shall
•comply with provisions of appendix IV (The Appendix IV to the Annex provides for Type Approval and Operating Limits of Shipboard Incinerators),
•Be approved by the administration against provisions of resolution MEPC.76 (40).
An operating manual shall be provided by the manufacturer.
The personnel responsible for the operation of the incinerator shall be trained and capable of implementing the guidance provided in the manual.
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MARPOL, ANNEX VI
PREVENTION OF AIR POLLUTION FROM SHIPS
SHIPBOARD INCINERATION (Reg.VI/16)
The incineration of the following substances is prohibited:
•residues from Marpol Annex I, II and III cargoes (and related packed materials),
•polychlorinated biphenils (PCBs),
•garbage (defined in MARPOL, Annex V) containing trace of heavy metals,
•refined petroleum products containing halogen compounds.
Incineration of sewage sludge and sludge oil generated during the normal operation of the ship may also take place in the main or auxiliary plant or boilers outside ports, harbours and estuaries.
Incineration of polyvinyl chlorides (PVCs) is prohibited, except in incinerators issued with an IMO Type Approval Certificate (MEPC.59 (33) or MEPC.76 (40)).
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MARPOL, ANNEX VI
PREVENTION OF AIR POLLUTION FROM SHIPS
FUEL OIL QUALITY (Reg.VI/18)
No comments
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MARPOL, ANNEX VI
PREVENTION OF AIR POLLUTION FROM SHIPS
FUEL OIL QUALITY (Reg.VI/18)
No comments
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MARPOL, ANNEX VI
PREVENTION OF AIR POLLUTION FROM SHIPS
FUEL OIL QUALITY (Reg.VI/18)
BUNKER DELIVERY NOTE
The details of fuel to be used on board for combustion purposes delivered to and used on board are recoded through a bunker delivery note.
The bunker delivery note contains information as required by Appendix V:
- Name and IMO number of the 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 15°C (kg/m3)
- Sulphur content (% m/m)
- A declaration signed and certified by the fuel oil supplier’s representative that the fuel oil supplied is in conformity with reg.14(1) or (4)(a) and reg.18(1) of the Annex.
The bunker delivery note is kept on board for a period of 3 years after the date of delivery and is made readily available for inspection.
The bunker delivery note is accompanied by a sample of the delivered fuel oil drawn in accordance with IMO Guidelines (MEPC. 96(47)). The sample is sealed and signed by the fuel oil supplier’s representative and the Master or officer in charge of bunker operations on completion of thebunkering operation. The sample is kept on board until the fuel oil is substantially consumed but for not less than 12 months from the delivery date.
PortState Control
The Port State Control Officer may inspect and copy any bunker delivery note. He may even require the Master or the person in charge of the ship to certify that each copy is a true copy of the bunker delivery note. He may verify the content of each note through consultation with the port where the note was issued.
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MARPOL, ANNEX VI
PREVENTION OF AIR POLLUTION FROM SHIPS
FUEL OIL QUALITY (Reg.VI/18)
LOCAL FUEL OIL SUPPLIERS
They are required by the appropriate authorities to:
- provide bunker delivery note and sample of fuel oil,
- keep copy of the bunker delivery note for three years.
DUTIES OF THE OWNERS/MANAGERS
They will have to ensure that:
•Fuel oils are supplied by suppliers registered with the appropriate authority of the country in which they operate,
•Bunker delivery notes are only accepted from the supplier if they are in line with the scope provided for in Appendix V, specifically the statement regarding the sulphur content.
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MARPOL, ANNEX VI
PREVENTION OF AIR POLLUTION FROM SHIPS
FUEL OIL QUALITY (Reg.VI/18)
DUTIES OF THE AUTHORITIES
The «appropriate authorities» have to:
•to maintain a register of local suppliers of fuel oil,
•take action against suppliers that have not found to deliver fuel complying with that stated on the bunker delivery note,
•inform Administration of ship receiving fuel oil non compliant with regulations 14 or 18 of the Annex,
•inform IMO of all cases where fuel oil suppliers have failed to meet the requirements specified in regulations 14 or 18 of the Annex.
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MARPOL, ANNEX VI
PREVENTION OF AIR POLLUTION FROM SHIPS
APPLICATION (Reg.I and 19)
No comments
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MARPOL, ANNEX VI
PREVENTION OF AIR POLLUTION FROM SHIPS
CERTIFICATION (Reg.6)
What are the ships/units subjected to certification?
- Ships of 400 GT and above, engaged in voyages to ports or offshore terminals under the jurisdiction of other parties
- Platforms and drilling rigs, engaged in voyages to ports or offshore terminals under the jurisdiction of other parties
New ships
Ships constructed on/after 19 May 2005 shall be issued with an International Air Pollution Prevention Certificate (IAPP) upon their delivery
Existing ships
Ships constructed before 19 May 2005 shall be issued with an International Air Pollution Prevention Certificate (IAPP) not later than the first scheduled dry-docking after 19 May 2005 but not later than 19 May 2008.
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MARPOL, ANNEX VI
PREVENTION OF AIR POLLUTION FROM SHIPS
SCOPE OF THE CERTIFICATION
SHIPS CONSTRUCTED ON/AFTER 1 JANUARY 2000OF 400 GT AND OVER
•ozone-depleting substances (reg.VI/12)
•nitrogen oxide (NOx) emissions from diesel engines (reg. VI/13)
•sulphur dioxide (SOx) emissions from ships (reg.VI/14)
•volatile organic compound (VOCs) emissions from cargo tanks of oil tankers (re.VI/15)
•shipboard incineration of waste (reg.VI/16)
•fuel oil quality (Reg.VI/18)
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MARPOL, ANNEX VI
PREVENTION OF AIR POLLUTION FROM SHIPS
SCOPE OF THE CERTIFICATION
SHIPS CONSTRUCTED BEFORE 1 JANUARY 2000OF 400 GT AND OVER
•ozone-depleting substances (reg.VI12)
•sulphur oxide (SOx) emissions from ships (reg.VI/14)
•volatile organic compound (VOCs) emissions from cargo tanks of oil tankers (reg.VI/15)
•shipboard incineration of waste (reg.VI/16)
•fuel oil quality (reg.VI/18)
Ships constructed before 1 January 2000are exempted from complying with provisions addressing nitrogen oxide (NOx) emissions from diesel engines (reg. VI/13) but shall comply with other applicable provisions of the Annex.
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MARPOL, ANNEX VI
PREVENTION OF AIR POLLUTION FROM SHIPS
SURVEYS (Reg.5)
This is the «old» schedule.
It is already intended to fit the surveys required by MARPOL, Annex VI, in line with the Harmonized System of Surveys and Certification (HSSC). A resolution has been approved by the MEPC at its 52nd session (11-15 October 2004).
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MARPOL, ANNEX VI
PREVENTION OF THE AIR POLLUTION FROM SHIPS
NOx TECHNICAL CODE
PRE-CERTIFICATION OF THE ENGINE: EIAPP CERTIFICATE
The mandatory NOx Technical Code defines the procedures and means by which a diesel engine is to be certified with regard to NOx emission controls.
The Code offers five alternative methods from which one can be chosen to measure, calculate or test an engine for its NOx emissions. At this stage, i.e. pending the entry into force of the Annex VI, the method which has been retained by the engine makers is the first method, Test-bed testing for pre-certification survey in accordance with Chapter V of the Code.
Upon satisfactory tests, the diesel engine is issued with an Engine International Air Pollution Prevention Certificate (EIAPP). Pending the entry into force of the Annex VI, the pre-certified diesel engines have been issued with either an Attestation or Document or Statement of Compliance.
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MARPOL, ANNEX VI
PREVENTION OF THE AIR POLLUTION FROM SHIPS
NOx TECHNICAL CODE
CERTIFICATION OF THE ENGINE
The certification of the engine is a prerequisite to the issuance of the International Air Pollution Prevention (IAPP) Certificate to a ship constructed on/after 1 July 2000.
The NOx Technical Code provides that a Technical File, related to the diesel engine and approved by the Administration, is placed on board the ship.
During the on board survey, a few options are offered to investigate the status of the engine with regard to its NOx emissions.
- Declaration from the engine manufacturer with regardto adjustments or modifications that could have been possibly made to the engine after its pre-certification and which could affect (or not affect) the NOx emission limits.
- Demonstration, using the on-board NOx verification procedures contained in the Technical File, that :
- No adjustment or modification have been made, or
- That the adjustments or modifications are within the approved limits documented in the Technical File.
If any adjustment or modification is found to be outside the approved limits, it shall be demonstrated that the NOx emissions still stay within the mandatory limits (Reg.VI/13).
Such a verification is conducted through :
- A direct on-board investigation monitoring, or
- A simplified on board NOx measurement, or
- A reference to an emission test performed for the relevant engine group and covering the particular adjustments or modifications (Technical Code, 2.3.11).
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MARPOL, ANNEX VI
PREVENTION OF THE AIR POLLUTION FROM SHIPS
ANNEX VI & ISM CODE
ADDITIONAL PROCEDURES
Owners/Managers have to ensure that operational requirements of the Annex VI are duly implemented and verifiable.
In addition to new procedures bound to the control of NOx and SOx, the procedures addressing refrigeration, fire-fighting systems, incineration and bunkering need to be updated in line with the requirements of the Annex VI.
NOx Control
The engine shall hold a valid EIAPP Certificate (Or a Document of Compliance).
A Technical File, incorporating modifications, if any, shall be maintained and retained onboard with the engine to which it relates.
The engine shall be operated in accordance with the duty, rating and restriction, if any, as specified within the Technical File.
Where the Onboard NOx verification procedure is based on the Parameter Check Method, the Engine Record Book need being accurately maintained. This is a document providing a chronological record of any change to the NOx components or settings (Adjustments, replacements, implementation of approved modification) as required by the NOx Technical Code.
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MARPOL, ANNEX VI
PREVENTION OF THE AIR POLLUTION FROM SHIPS
ANNEX VI & ISM CODE
ADDITIONAL PROCEDURES
SOx Control
Except when operating within a SOx Control Emission Area where the sulphur limit is 1.5%, fuel oils for onboard use shall be ordered with a sulphur content of less than 4.5% and that shall be verified from the bunker receipt.
Where a ship is entering a SOx Control Emission Area, it is necessary to have onboard an adequate quantity of fuel oil the sulphur content of which does not exceed 1.5%. Before entering the Area, in addition, the fuel oil system shall be flushed of fuel oils exceeding 1.5% of sulphur content and the system shall be changed over to fuel oils of less than 1.5%.