Guidance Notes on the Prevention of Air Pollution from...

GUIDANCE NOTES ON

PREVENTION OF AIR POLLUTION FROM SHIPS

MARCH 1999

American Bureau of Shipping Incorporated by Act of the Legislature of The State of New York 1862

Copyright © 1999 American Bureau of Shipping Two World Trade Center, 106th Floor New York, NY 10048 U.S.A.

These Guidance Notes are intended to address sources of air pollution from ships and other marine structures, and options for prevention and/or reduction of such emissions. ABS assumes no responsibility for the use of or failure to use these Guidance Notes. The Guidance Notes provide information for consideration in the design and operation of ships both before and after entry into force of Annex VI of MARPOL 73/78 on Regulations for the Prevention of Air Pollution from Ships. Nothing in these Guidance Notes shall be deemed to relieve any naval architect, designer, builder, owner or other entity or person of the need to exercise professional judgement, nor of any warranty, expressed or implied. Nothing in these Guidance Notes replaces or alters any IMO Guidelines or the statutes and regulations of the flag Administrations.

FOREWORD

in September 1997 a Diplomatic Conference was held at the international Maritime Organization (IMO) in London which resulted in the adoption of a sixth Annex to the International Convention for the Prevention of Pollution from Ships, 1973, as modified by the Protocol of 1978 relating thereto (MARPOL 73/78). Annex VI is concerned with the prevention of air pollution from ships but, unlike the other Annexes to MARPOL, may not always be bound by the traditional requirements for entry into force, namely "12 months after the date on which not less than 15 States, the combined merchant fleets of which constitute not less than 50 per cent of the gross tonnage of the world's merchant shipping, have become parties to the 1997 Protocol".

The new Annex has been under development at the IMO for a period in excess of 8 years but the subject of ship generated air pollution has been a topic of discussion for much longer. Environmentalists have long argued that shipping should be held accountable for its share of global pollution but it is only recently, as a direct result of the imposition of increasingly more stringent land-based air pollution reduction strategies in many parts of the world, that shipping's overall contribution to global air pollution has become more significant.

Annex VI differs from the other Annexes to MARPOL in so much as the effects of air pollution are not necessarily evident at their point of discharge, as is the contamination of the sea by oil, chemicals, garbage or raw sewage. Indeed, the effects of air pollution may be felt many hundreds of miles from its source and even land-locked countries are not immune to it, as they are to other forms of marine pollution. Because of this transboundary effect of air pollution, and the compelling need for many countries to tackle the growing problems of its effects on human health and terrestrial/aquatic ecosystems, the IMO has agreed to recommend the early implementation of controls to reduce both emissions of nitrogen oxides (N0x) from new marine diesel engines, and harmful discharges from

shipboard incinerators. It has also been agreed that, in order to avoid unacceptably long delays in the entry into force of Annex VI (as is the ease with Annex IV of MARPOL on the Prevention of Pollution by Sewage which has still not entered into force some 25 years after its adoption), the Marine Environment Protection Committee of the IMO will review the standard entry into force requirements and the contents of the Annex if it has not entered into force by 31 December 2002.

The aim of these Guidance Notes is to identify those regulations in the new Annex which require to be addressed immediately as against those which should be considered in the medium to long tern. Types of pollution which have been omitted from the Annex, but which are being actively discussed at the IMO are also identified as are those pollutants which are already controlled but where more stringent controls are likely to be introduced in the medium to long term.

This guide will be of interest to owners and operators of ships, offshore platforms, drilling units and other marine structures as wrell as surveyors, builders, designers and manufacturers of marine equipment. It should be read in conjunction with the IMO publication "Annex VI of MARPOL 73/78, Regulations for the Prevention of Air Pollution from Ships and NOx Technical Code"

available from the IMO Publications Department, Sates No. IMO-664E.

Finally, ABS would like to express its gratitude to the Institute of Marine Engineers for granting permission to include extracts of a previous paper by Colin S. Brookman, the Author, entitled "Exhaust Gas Monitoring" which was presented at the Tenth International Maritime and Shipping Conference (IMAS 96) on "SHIPPING AND THE ENVIRONMENT — Is Compromise Inevitable". Copies of the Conference Proceedings are available from the Institute of Marine Engineers reference ISBN 0-907206-77-8.

ABS GUIDANCE NOTES ON PREVENTION OF AIR POLLUTION FROM SHIPS, MARCH 1999

GUIDANCE NOTES ON


CONTENTS

Section

Section compliance from 01 January 2000) 7

1 General 9

3 New diesel engines and the NOx Technical Code 10

5 Incinerators 11

SECTION 3 Control of Other Pollutants (Before & after entry into force of Annex VI) 13

1 General 15

3 Ozone Depleting Substances 16

5 Sulfur Oxides (SOX) 16

7 Volatile Organic Compounds (VOC's) 17

9 Fuel Oil Quality 19

SECTION 4 Compliance With Annex (Including a review of some of the options available) 21

1 General 23

3 Chapter I - General 23

5 Chapter II - Survey, Certification and Means of Control 24

7 Chapter III - Requirements for Control of Emissions from Ships 25

SECTION 5 The Future 41

1 General 43

3 Future emission controls 43

5 Future Technology 45

1 Introduction 1

1 Background 3

3 Contents of the new Annex 4

5 Effects on Shipping 5

7 Why Shipping 5

2 Retrospective Regulatory Compliance (Early

ABSR GUIDANCE NOTES ON PREVENTION OF AIR POLLUTION FROM SHIPS, MARCH 1999 iii

SECTION 6 Conclusions 51

APPENDIX 1

APPENDIX 2

APPENDIX 3

APPENDIX 4

APPENDIX 5

ANNEX

APPENDIX 6

APPENDIX 7

Chapter III of Annex VI on the Requirements for Control of Emissions From Ships 55

Information to be Included in the Bunker Delivery Note (Regulation 18(3)) 65

Notification to the Organization on Ports or Terminals where Volatile Organic Compounds (VOCs) Emissions are to be Regulated 67

Definitions 69

Interim Guidelines for the Application of the NOx Technical Code 73

INTERIM GUIDELINES FOR THE APPLICATION OF THE NOx TECHNICAL CODE 75

Check Sheet for an Engine Parameter Check Method 77

Useful Web Site Addresses 79

iv ABS1' GUIDANCE NOTES ON PREVENTION OF AIR POLLUTION FROM SHIPS, MARCH 1999

ABBREVIATIONS AND SYMBOLS (As used in the Guidance Notes)

ABS American Bureau of Shipping

Annex I (of MARPOL 73/78) on the Prevention of Pollution by Oil

Annex II (of MARPOL 73/78) on the Control of Pollution by Noxious Liquid Substances in Bulk

Annex III (of MARPOL 73/78) on the Prevention of Pollution by Harmful Substances carried by Sea in Packaged Form

Annex IV (of MARPOL 73/78) on the Prevention of Pollution by Sewage

Annex V (of MARPOL 73/78) on the Prevention of Pollution by Garbage from Ships

Annex VI (of MARPOL 73/78) on the Prevention of Air Pollution from Ships

BDC Bottom dead center

CFC Chiorofluorocarbon

CFR Code of Federal Regulations (US)

Circ. Circular

CO Carbon monoxide

COC Certificate of Compliance

CO2 Carbon dioxide

DE Design & Equipment Sub-Committee (of the IMO)

EGR Exhaust gas recirculation

EIAPPC Engine International Air Pollution Prevention Certificate

EMEP Co-operative Programme for Monitoring & Evaluation of Long Range Transmission of Air Pollutants in Europe

FCCC Framework Convention on Climatic Change

FPSO Floating production, storage & offloading (facility)

FSU Floating storage unit

gfkWh Grams per kilowatt hour

GWP Global warming potential

HAM Humid air motor

HC Hydrocarbon

HCFC Hydrochlorofluorocarbon

HCI Hydrogen chloride

HF Hydrogen fluoride

ABS" GUIDANCE NOTES ON PREVENTION OF AIR POLLUTION FROM SHIPS, MARCH 1999

Hg

IAPPC

IMO

ISO

kW

LNG

LRTAP

m

mlm

Mercury

International Air Pollution Prevention Certificate

International Maritime Organization

International Standards Organization

Kilowatt

Liquefied natural gas

Convention on Long Range Transboundary Air Pollution

Meter

Cubic meter

Mass per unit mass

MARPOL International Convention for the Prevention of Pollution from Ships, 1973, as modified by the Protocol of 1978 relating thereto (MARPOL 73/78)

MEPC Marine Environment Protection Committee (of the IMO)

mg Milligram

MJ Megajoule

MSC Maritime Safety Committee (of the IMO)

n Engine speed in rpm

NH3 Ammonia

nm Nanometer

NO Nitric oxide

NO2 Nitrogen dioxide

NOx Nitrogen oxides

02 Oxygen

03 Ozone

ODP Ozone depleting potential

PCB Polychlorinated biphenyl

PFC Perfluorocarbon

PM Particulate matter

ppm Parts per million

PSC Port State control

PVC Polyvinyl chloride

R11, R115 etc Standard refrigerant identification numbers

rpm Revolutions per minute

SCR Selective catalytic reduction

vi ABS GUIDANCE NOTES ON PREVENTION OF AIR POLLUTION FROM SHIPS, MARCH 1999

SO2 Sulphur dioxide

SOLAS International Convention for the Safety of Life at Sea, 1974 and its Protocol of 1978

SOX Sulphur oxides

SOXECA Sulphur oxides emission control area

TBN Total base number (oil)

TBT Tributyltin

TR Technical report

UK United Kingdom

UN United Nations

UNCLOS United Nations Convention on Law of the Sea

UNFCCC United Nations Framework Convention on Climatic Change

USA United States of America

VECS Vapor emission control system

VIT Variable injection timing

VLCC Very large crude carrier

VOC Volatile organic compound

ABS'' GUIDANCE NOTES ON PREVENTION OF AIR POLLUTION FROM SHIPS, MARCH 1999 vii

GUIDANCE NOTES ON

PREVENTION OF AIR POLLUTION

FROM SHIPS

SECTION 1 Introduction

CONTENTS

Background 3

3 Contents of the new Annex 4

5 Effects on Shipping 5

7 Why Shipping 5

ABS1' GUIDANCE NOTES ON PREVENTION OF AIR POLLUTION FROM SHIPS, MARCH 1999 1

GUIDANCE NOTES ON


SECTION 1 Introduction

'I Background

1.1 Whilst there are many sources of air pollution in the modem world, the continuing use of fossil fuels remains the largest single contributor to atmospheric pollution. Ever since sail gave way to mechanical power, as the predominant method of propulsion, shipping has contributed to this pollution; in the past this has largely been ignored because, compared to land-based sources, shipping's contribution was considered negligible. It is only in the last ten years or so, as a direct result of increasingly stringent abatement technology being applied ashore, that ships' emissions, particularly exhaust gases, are no longer considered insignificant.

1.3 Recent studies have indicated that ships exhaust emissions may now be responsible for up to 14% of the worldwide nitrogen oxides (N0x) emissions and approximately 8% of sulfur oxides (S0x) emissions although these figures have been disputed by the international shipping community based on the annual consumption of bunker oil fuel which, at some 140 million tonnes, only accounts for approximately 4% of the world's total oil fuel consumption. However, earlier publicity given to somewhat lower estimates of NO & SO„ emissions, coupled with evidence of damage to human health and terrestrial/aquatic ecosystems resulting from other pollutants such as Halons, Chlorofluorocarbons (CFCs), Volatile Organic Compounds (VOCs) and the products of combustion from shipboard incinerators, prompted the International Maritime Organization (IMO) to place air pollution on the agenda of the Marine Environment Protection Committee (MEPC) towards the end of the 1980s.

1.5 After some 8 years of often passionate arguments a new Air Pollution Annex was finally adopted by a MARPOL Diplomatic Conference in September 1997. The adoption of the Annex was by means of the Protocol of 1997 to amend MARPOL 73/78 and, at the same time, a number of Conference Resolutions were also adopted including four which are likely to have a profound effect on the operation of shipping over the coming years, they are:

ABS' GUIDANCE NOTES ON PREVENTION OF AIR POLLUTION FROM SHIPS, MARCH 1999 3

Section 1 Introduction

1,5.1

Resolution No. 2 on the Technical Code on Control of Emission of Nitrogen Oxides from Marine Diesel Engines (The NO Technical Code);

Resolution No. 3 on Review o 'Nitrogen Oxides Emission Limitations;

Resolution No. 7 on the Restriction on the Use of Perfluorocarbons (PFCs) on board Ships; and,

Resolution No. 8 on Carbon. Dioxide (CO2 ) emissions from Ships.

3 Contents of the new Annex

3.1 Annex VI is split into three sections or chapters; Chapter covers general requirements, Chapter II deals with survey, certification and means of control whilst Chapter III provides requirements for control of emissions from ships. Chapters I & II closely follow the format of previous MARPOL Annexes with regard to the titles and content of the regulations with only minor changes reflecting emissions to the atmosphere rather than discharges to the sea. The regulations contained in Chapter HI will effectively control the discharge or emission of a number of substances, which presently contribute to global air pollution, and will apply to both new and existing ships depending on the type of pollutant being controlled.

3.1.1

Halons, such as are found in fire extinguishing systems, will be banned in all new installations (including portable extinguishers) although existing installations remain unaffected at present.

3.1.2

Chlorofluorocarbons (CFCs) and other ozone depleting substances, such as are used in refrigeration plants and for the production of certain types of insulation material, will be banned in all new installations although existing installations remain unaffected at present. New installations containing hydrochlorofluorocarbons (HCFCs) will, however, be permitted until 1 January 2020.

3.1.3

Nitrogen oxides (NO,,) emissions, which contribute to acid deposition and result in the

formation of ground level ozone (which can cause breathing problems in some vulnerable people and is formed in varying amounts during the combustion process in petrol and diesel engines, gas turbines, boilers and incinerators) will only initially be regulated in new diesel engines.

3.1.4.

Sulfur oxides (SO.j emissions, which are the other main cause of acid deposition, will be

regulated in all ships.

1.5.2

1.5.3

1.5.4

4 ABS' GUIDANCE NOTES ON PREVENTION OF AIR POLLUTION FROM SHIPS, MARCH 1999

Section 1 introduction

3.1.5

Volatile organic compounds (VOCs), which are mainly given off during cargo operations on certain oil, gas and chemical tankers, will only be regulated when so required by individual Administrations for ports and terminals under their jurisdiction.

3.3 In addition to legislation on the substances noted above, the design and operation of shipboard incinerators will be further regulated whilst the quality of fuel oil supplied to ships will also be controlled and monitored, the combustion of sub-standard fuel being one of the prime causes of certain types of air pollution. The provision of adequate reception facilities and application of the new Annex to Platfouns and Drilling Rigs are also addressed. For ease of reference a copy of Chapter [II of Annex VI, Regulations 12 through 19, is included as appendix 1 to these Guidance Notes.

5 Effects on Shipping

5.1 Unlike the three "optional" Annexes to MARPOL (III, IV & V) which have been adopted by the IMO (only two of which have thus far entered into force), Annex VI has been introduced by means of a Protocol and, upon entry into force, will require all Convention ships of Parties to MA.RPOL 73/78 to be issued with an International Air Pollution Prevention Certificate. Prior to the issuance of this statutory certificate the flag State, or a Recognised Organization acting on its behalf (e.g. a Classification Society such as ABS), will need to confirm compliance with the applicable regulations contained within the Annex; the certificate's continuing validity will require annual, intermediate and renewal surveys to be satisfactorily carried out and, being a statutory certificate, it will come under the scrutiny of port State control inspectors wherever the ship plies her trade.

5.3 Whilst the majority of Annex VI will only apply to new and existing ships after entry into force of the 1997 Protocol there are two regulations which will be applied retrospectively from 01 January 2000, namely Regulation 13 on NOx and Regulation 16 on shipboard incinerators, where a new ship will be defined as one constructed on or after that date. For further details refer to section 2 of these Guidance Notes.

7 Why Shipping

7.1 Why the sudden interest in shipping which, after all, is considered by many to be the most environmentally friendly method of transporting cargoes around the world; as has been stated earlier, this is in no small way due to the pressures that have been placed upon industry ashore to demonstrate compliance with increasingly more stringent emission standards.

7.3 Many countries have legislation in place to control or prevent air pollution, some of which is internally driven but most being as a direct result of international Conventions and their associated Protocols: for the protection of the ozone layer there is the Vienna Convention and its related Montreal Protocol; the Framework Convention on Climatic Change (FCCC) is primarily concerned with greenhouse gas emissions whilst some 40 States in and around the European landmass, together with the USA and Canada, are signatory to the Convention on Long Range Transboundary Air Pollution (LRTAP), This latter Convention has five related Protocols which have also been ratified

ABS''' GUIDANCE NOTES ON PREVENTION OF AIR POLLUTION FROM SHIPS, MARCH 1999 5

Section 1 Introduction

by various parties to that Convention and have now entered into force, namely: the 1984 Protocol on the Co-operative Programme for Monitoring and Evaluation of the Long Range Transmission of Air Pollutants in Europe (EMEP); the 1985 Sulfur Protocol; the 1988 NO,, Protocol; the 1991 VOC

Protocol; and, the 1994 Sulfur Protocol. A further two Protocols to the Convention have been approved and are presently open for signature by contracting Parties, these are the 1998 Heavy Metals Protocol and the 1998 Persistent Organic Pollutants Protocol.

7.5 It is interesting to note that the LRTAP Convention and existing Protocols do not address shipping although this may change with the development of the second step to the NO Protocol where a multi-

pollutant approach will be applied, addressing photochemical pollution, acidification and eutrophieation a draft Protocol could be tabled by the end of 1999 and it is envisaged that it will contain technical annexes on emissions from mobile sources, including shipping. In the mean time the United Nations Convention on Law of the Sea (UNCLOS), which acts as an "umbrella" treaty for international shipping, remains the sole guardian of the atmosphere but only up to 200 miles from a coastal State's coastline.


GUIDANCE NOTES ON


FROM SHIPS

SECTION 2 Retrospective Regulatory Compliance (Early compliance

from 01 January 2000)

CONTENTS

1 General 9

3 New diesel engines and the NOx Technical Code 10

5 Incinerators 11


GUIDANCE NOTES ON


FROM SHIPS

SECTION 2 Retrospective Regulatory Compliance (Early compliance from 01 January 2000)

General

1.1 Whilst Annex VI is not enforceable, internationally, until such time as it enters into force there are two regulations which will be retrospectively applied in many areas of the world on the date of entry into force of the Annex. These regulations concern NO emissions from "new" and "substantially

modified" diesel engines (Regulation 13) and "new" Shipboard Incinerators (Regulation 16), both of which refer to a compliance date of 01 January 2000 regardless of the date of entry into force of Annex VI. Actual compliance with the pertinent parts of these regulations after Ol. January 2000, whilst not mandatory, is recommended for the following reasons:

It is far easier, and more cost effective, to order equipment to be supplied in accordance with new specifications, than attempt to upgrade existing equipment to meet standards for which it was not originally designed;

1.1.2

The time scale between the Annex meeting the entry into force requirements and its actual date of entry into force is only 12 months, which may well be insufficient to arrange compliance with those regulations and/or standards;

1.1.3

A flag State's introduction of domestic legislation, prior to entry into force, to enable it to become a Party to the Protocol of 1997 by "signature without reservation, acceptance or approval" may mean its own vessels being required to fully comply before entry into force of the Annex; and,


Section 2 Retrospective Regulatory Compliance

1.1.4

Non-compliance after entry into force of Annex VI may well result in a port State detention, and/or prohibition from trading to and from that port or coastal State until such time as compliance can be demonstrated.

1.3 Irrespective of the above, it is ultimately the Owner's responsibility to ensure that his vessel complies with the national regulations of the State, the flag of which his ship is entitled to fly; this may well include early compliance with Regulations 13 & 16, and may also require interim measures to be taken to reduce emissions of other pollutants covered by the Annex. For those flag States who have authorized ABS to act on their behalf instructions on the degree of compliance required will be available through the local ABS Office. Early confirmation of a flag State's requirements, either directly, or through ABS, is therefore strongly recommended.

3 New diesel engines and the NO Technical Code

3.1 The NO Technical Code was developed by a small group of experts within the IMO and is of a

highly technical nature, being based on the relevant parts of the International Standards Organization publication ISO 8178 and providing a common basis for the NO testing of marine diesel engines. It

also includes information on certification procedures for different types of engines as well as onboard verification procedures for demonstrating continuing compliance with the applicable NO emissions

limits. Due to the size of the NO Technical Code it has not been reproduced as an appendix to

these Guidance Notes.

3.3 Regulation 13 of Annex VI basically requires that all diesel engines with individual power outputs greater than 130 kW, which are installed on ships operating internationally and constructed on or after 01 January 2000, comply with the applicable NO„ emission limits as set out in Regulation

13(3)(a) and chapter 3 of the NO Technical Code. Engines undergoing major conversion after 01

January 2000, as defined in Regulation 13(2)(a) and 1.3.2 of the NO Technical Code, are also

included but diesel engines for emergency use, and those installed on vessels solely engaged in domestic trade are exempt providing they meet the requirements laid down in sub-paragraphs (b) & (c) of Regulation 13(1). The Annex does not address NO„ emissions from ships boilers, gas turbines

or incinerators although this may change in the future. For further information on future emission controls refer to section 5 of these Guidance Notes.

3.5 As has already been explained, until such time as the Annex enters into force its regulations are unenforceable; this means that for Regulation 13, although an engine may have been certified as being NO„ compliant at the time of its manufacture, evidence of continuing compliance may not be

required until such time as the initial survey for issuance of the International Air Pollution Prevention Certificate (IAPPC) is carried out. The issuance of such a certificate to ships constructed before the date of entry into force of the Annex, as per MARPOL VI/6(2), may be delayed by up to 3 years.

10 ABS'' GUIDANCE NOTES ON PREVENTION OF AIR POLLUTION FROM SHIPS, MARCH 1999


ACTION In order to avoid the retrospective regulatory compliance problems associated with NO emissions, prudent Owners should ensure that diesel engines installed on ships constructed on or after 01 January 2000, and diesel engines which undergo a major conversion on or after that date, are:

• "certified" in accordance with the NO Technical Code,'

• supplied with an "approved Technical File"; and,

• maintained in continuing compliance with the relevant NO emission limits including "documentary evidence" of same.

Note 1: The term "certified", as used in the above context, is taken to mean that an engine has been pre-certified and/or certified by an authorized Authority such as the vessel's flag Administration or a Recognised Organizationl acting on its behalf in accordance with the requirements of 2.2 and 2.3 respectively of the NO, Technical Code. Prior to entry into force of Annex VI this "certification" should take into consideration the contents of MEPC/Circ.344.

Note 2: The term "approved Technical File" is taken to mean a Technical File meeting the requirements of 2.4.1 of the NO Technical Code and approved by an authorized Authority such as

the vessel's flag Administration or a Recognised Organization acting on its behalf,

Note 3: The term "documentary evidence" is taken to mean a properly completed Record Book of Engine Parameters, or records of onboard emission testing either by the simplified measurement method or by direct measurement and monitoring, all in accordance with the relevant sections of chapter 6 of the NOx Technical Code.

3.7 Further infotination on options for the control of NO emissions, as well as brief descriptions on the certification of engines, the Technical File, the Record Book of Engine Parameters and onboard NO measurement can be found in section 4.7.3 of these Guidance Notes.

5 Incinerators

5.1 Regulation 16 of Annex VI requires that all shipboard incinerators installed on ships on or after 01 January 2000 are approved by the Administration based on the requirements contained in IMO Resolution MEPC 76(40) on Standard Specification for Shipboard Incinerators; such incinerators must also be operated within the limits laid down in section A1.5 of Annex 1 of MEPC 76(40), which is reproduced in section 4.7.9.1 of these Guidance Notes. Regulation 16(4) prohibits the incineration of MARPOL Annex I, II & III cargo residues and related contaminated packing materials, polychlorinated biphenyls (PCBs), garbage contaminated with heavy metals and refined petroleum products containing halogen compounds. The incineration of sewage sludge and sludge oil, generated during the normal operation of the ship, is allowed in main or auxiliary power plant or boilers as per Regulation 16(5) but incineration by such methods is banned in ports, harbours and estuaries.

ABS is a Recognised Organization and is authorized to issue statutory certification for most Administrations; the local ABS Office will be able to advise whether ABS has been authorized by a specific flag Administration to issue the relevant certification for Annex VI and the NQ Technical Code.



5.3 Incinerators installed on board ships prior to 01 January 2000, the vast majority of which have already been approved in accordance with the earlier version of the Standard Specification for Shipboard incinerators contained in IMO Resolution MEPC 59(33), may still be used after entry into force of the Annex although the incineration of polyvinyl chlorides (PVCs) in them will be prohibited by Regulation 16(6). Incinerators installed on vessels solely engaged in domestic trade may be exempted from the 01 January 2000 deadline but only up to entry into force of the Annex.

5.5 As with the NO regulation, until such time as the Annex enters into force Regulation 16 is

unenforceable; this means that although an incinerator may have been type approved in accordance with MEPC 76(40) at the time of its manufacture, evidence of its operation within the prescribed limits and operator training may not be required until such time as the initial survey for issuance of the IAPPC is carried out.

ACTION in order to avoid the retrospective regulatory compliance problems associated with incinerators, prudent Owners should ensure that incineration equipment "installed" on board ship on or alter 01 January 2000 is:

• "approved" in accordance with resolution MEPC 76(40);

• supplied with a manufacturer's operating manual;

•

operated only by competent personnel; and,

• maintained in a condition which allows operation within the prescribed limits at all times.

Note 1: The term "approved", as used in the above context, means type approved by an authorized Authority such as the vessel's flag Administration or a Recognized Organization acting on its behalf.

Note 2: The term "installed", as used in the above context means that for existing ships the incinerator is completely connected and ready for light-off. For new ships the term "installed" is taken to mean installed on ships constructed on or after 01 January 2000.

Note 3: Incinerators with capacities greater than 1500 kW cannot, by definition, be type approved in accordance with the current version of MEPC 76(40). However, experience has shown that where such incinerators are installed on vessels, flag Administrations have been agreeable to a "Statement of Compliance" with MEPC 76(40) being issued in lieu of the required IMO type approval certification.

12 ABS' GUIDANCE NOTES ON PREVENTION OF AIR POLLUTION FROM SHIPS. MARCH 1999

ABS

GUIDANCE NOTES ON PREVENTION OF AIR POLLUTION FROM SHIPS

SECTION 3 Control of Other Pollutants (Before & after entry into force of Annex VI)

CONTENTS

1 General 15

3 Ozone Depleting Substances 16

5 Sulfur Oxides (SOX) 16

7 Volatile Organic Compounds (VOC's) 17

9 Fuel Oil Quality 19


Section 3 Control of Other Pollutants

3 Ozone Depleie. Substances

3.1 Regulation 12 of Annex VI, upon entry into force, will prohibit the deliberate emission of ozone depleting substances such as halons and chlorofluorocarbons (CFCs) unless the safety of the ship and its passengers and/or crew is likely to be jeopardized. for example where a halon system is discharged for fire fighting purposes. Deliberate emissions do not include minimal releases of ozone depleting substances associated with system commissioning, maintenance or decommissioning; however leaks, whether deliberate or otherwise, may be regulated by flag or coastal States. The regulation also requires that all of the substances covered by the regulation, as well as machinery and equipment containing same, should be delivered to appropriate reception facilities upon removal from ships. The provision for reception facilities is covered by Regulation 17 of Annex VI and is further discussed in section 4.7.11 of these Guidance Notes.

33 The cut-off dates referred to in Regulation 12 are based on those contained in the relevant sections of the Montreal Protocol (as amended); the use of Halon in new fixed fire fighting installations has already been banned under SOLAS as of 1st October 1994 (SOLAS 11-2/5.3.1), and [MO is considering similar action for portable halon extinguishers. The use of CFCs (mainly utilized in air conditioning and refrigeration units) will be prohibited in all new installations after entry into force of Annex VI although many areas of the world have already banned their use in land based industrial and non-industrial machinery, this in many cases includes marine applications as well. Hydro-chlorofluorocarbons (HCFCs) will be permitted in new installations until 01 January 2020, but again there are areas in the world, for example the European Union, where these gases may become unavailable earlier due to a more severe regional phase-out schedule than that required by international regulation.

CAUTION Whilst some equipment containing or utilizing CFCs will still he available fir use in new installations prior to entry into force of Annex VI, prudent Owners should take into consideration the likely availability of replacement gases in the areas of operation of their vessels. Consideration should also he given to any impending legislation from a vessel's flag State, or indeed coastal States, should a vessel he employed on a dedicated service or route. As the production of ozone depleting substances is reduced and eventually ceases, the only reliable source of replenishment for existing plant is likely to be an ever dwindling stock of recycled gases available from the .Halon and CFC International Banking Systems which have been developed to conserve existing stocks of the gases for essential users.

5 Sulfur Oxides (SOX}

5.1 Regulation 14 on the control of emissions of SO, will, unlike the NO regulation, apply to all ships

upon entry into force of Annex VI and will also apply to every type of combustion equipment regardless of its end use, whether that be propulsion, power generation. auxiliary machinery or for emergency purposes. There will, however, be a period of grace to allow vessels time to comply with this regulation where, for instance, structural alterations are required to account for changes in onboard fuel oil tank arrangements and fuel oil distribution systems.

16 ABS" GUIDANCE NOTES ON PREVENTION OF AIR POLLUTION FROM SHIPS, MARCH 1999

GUIDANCE NOTES ON


FROM SHIPS

SECTION

3 Control of Other Pollutants (Before & after entry into force of

Annex VI)

11 General

1.1 Regardless of the type of pollutant being considered, control measures to reduce or prevent the local effects of an individual, or group of pollutants will very much depend on national legislation already enacted within the territories of a flag State, usually as a result of regional problems and/or international regulations. We have already identified, in section 1, the various Conventions and Protocols which cover the majority of the pollutants regulated in Annex VI; however, the international shipping community may be forgiven if it is unaware of many of these restrictions because, to date, shipping has been excluded from the direct controls imposed on land-based industry. This scenario will change with entry into force of the new Annex but in the interim period some of those pollutants, although not directly regulated on a world-wide basis, will be controlled by virtue of regional market forces; a good example of this is ozone depleting substances which are gradually being phased out because of a ban on their production in the major industrial nations.

1.3 As with other pollutants already discussed in these Guidance Notes the prudent shipowner will ascertain, either through the flag Administration or local ABS Office, which pollutants are the subject of regional or local control prior to ordering equipment containing or producing same. Indeed, depending on the source of such equipment, national legislation within the country of origin may well dictate lower levels of certain controlled pollutants than those to be imposed by MARPOL Annex VI.

ABS' GUIDANCE NOTES ON PREVENTION OF AIR POLLUTION FROM SHIPS. MARCH 1999 15


5.3 Regulation 14(1) mandates a global cap of 4.5% mini for the sulfur content of any oil fuel intended for use on board ships; Regulation 14(4) places additional controls on designated Special Areas, which are to be known as SO, Emission Control Areas (SO,ECAs), where the maximum sulfur

content of any fuel oil used will be further limited to 1.5% rn/rn (or, where post combustion treatment is utilized, the emission rate will be limited to a maximum of 6.0 g SOX/kWh). The sulfur content of

each parcel (bunker lifting) of oil fuel intended for use on board ship will also require to be documented by means of a "Bunker Delivery Note" which must be kept on board for a period of 3 years after delivery of the fuel to which it relates. Information to be included in the bunker delivery note required by Regulation 18(3) is included as appendix V to Annex VI and reproduced as appendix 2 to these Guidance Notes.

5.5 SO, Emission Control Areas will be strictly controlled by Annex VI with criteria and procedures for

their designation contained as appendix III to that Annex. At the time of adoption of the new Annex in September 1997 the only area designated as a SO, Emission Control Area was the Baltic Sea;

however, the North Sea States are presently preparing a case for the designation of the North Sea which, if successful, is likely to become effective upon entry into force of the new Annex. As has already been stated, options for compliance with the emission limits of a SOXECA are presently

limited to the use of low sulfur fuel, or utilization of an exhaust gas cleaning system as per Regulation 14(4)(b) of the Annex. Where fuel switching is to be used for compliance with the lower limits, change-over to the lower sulfur fuel will have to be carried out in such a manner as to ensure that all the higher sulfur fuel is flushed out of the system prior to entry into the SOXECA as per

Regulation 14(6). For further details refer to section 4.7.5 of these Guidance Notes.

5.7 There is also a requirement, at Regulation 14(2), to monitor the world-wide average sulfur content of residual fuel oil which, whilst not directly affecting the shipowner, will initially be calculated based on the results of fuel oil samples submitted, by owners, to the three major bunker fuel oil testing companies, of which ABS Oil Testing Services is one.

CAUTION Whilst the regulation pertaining to SO, ECAs will not become effective until at least

12 months after entry into . force of the Annex prudent Owners, when considering specifications Jri . future new buildings, may wish to take into account the likely areas of operation of those new vessels with respect to existing or proposed SO„ Emission

Control Areas. For those vessels which will be trading in and out of ports within SO, ECAs, on more than an occasional basis, an early review of fuel oil storage and

distribution systems to cater for high and low sulfiir fuels, or of alternative exhaust gas cleaning systems, should be carried out. Methods of compliance with this regulation are more 'idly discussed in section 4.7.5 of these Guidance Notes.

7 Volatile Organic Compounds (VOC's)

7.1

Regulation 15 deals with the control of emissions of Volatile Organic Compounds (VOC's) from oil chemical and gas tankers only but, unlike other pollutants covered by the Annex, VOC's are not to be universally controlled. In order for a port or terminal to be designated as a VOC control area it will be necessary for the relevant coastal State Administration to declare that port or terminal as such to the Organization (MO), provided of course that the Administration is signatory to the 1997 Protocol (Annex VI). Not all ports and terminals under the jurisdiction of an Administration may be



affected by such a declaration and not all types and sizes of tankers visiting ports or terminals, which are to be controlled, will necessarily be required to comply with the regulations as it will be up to the Administration to designate cargo types and tanker size as well as ports and terminals to be controlled.

Before an Administration can declare a port or terminal a VOC control area that port or terminal must be provided with a vapor emission control system (VECS) which is in compliance with the safety standards laid down in MSC/Circ.585 on Standards for Vapour Emission Control Systems. Tankers using a port or terminal, which is subject to VOC emission controls during loading, must be fitted with a means of collecting VOCs for return of same to the shoreside facilities and this system must also be in compliance with the requirements of MSC/Cire.585, thus ensuring compatibility between ship and shore.

7.3

7.5 A number of countries, including the USA, UK and Norway, already have ports or terminals under their jurisdiction fitted with vapor emission control systems, either on a voluntary basis or as a result of legislation enacted under the 1991 VOC Protocol to the LRTAP Convention. What is not clear, at present, is whether or not the operations of Floating Production, Storage and Off-loading facilities (FPSOs) and Floating Storage Units (FSUs) are to be included under this regulation as, technically, when operating within the jurisdiction of a coastal State, they could be classed as terminals. The IMO is currently considering the role of drilling and production platforms, FPSOs and FSUs under a general review of MARPOL and its applicability to the operations of such vessels; it should also be noted that there are no internationally agreed safety standards presently available for controlling VOC emissions from such vessels during loading (from a well) and discharging to shuttle tankers.

It is the Administration's responsibility to ensure that the IMO is advised as to which of its ports or terminals will be subject to VOC controls, which cargoes will be controlled, the size of ships to be controlled and the effective date of implementation of such controls. It is the Owner's responsibility to ensure that his vessels are equipped in accordance with the requirements of MSC/Circ.585 prior to entry into ports or terminals where VOC controls are being implemented.

7.7

7.9 As has been stated above a number of countries have already installed, or are in the process of installing, vapor emission control systems in some of their ports or terminals in order to combat local problems associated with VOCs. In some ports their use is optional but in many it is mandatory with some vessels being denied access to ports if they are not fitted with an approved VECS, this however is a rare occurrence as non-compliant vessels are usually sifted out at the chartering stage. The IMO, in recognition of the fact that there has been an increase in the number of ports and terminals declaring controls on VOC emissions prior to entry into force of the new Annex, adopted, at the MEPC's 42'1 session, MEPC/Circ.345 on "Notification to the Organization on Ports or Terminals where Volatile Organic Compounds (VOCs) Emissions are to be Regulated". The purpose of the circular is to allow the IMO to collate and distribute, to its members, details of ports and terminals regulating VOCs and conditions imposed on ships using those ports. A copy of the circular is included as appendix 3 to these Guidance Notes.

18 ABS} GUIDANCE NOTES ON PREVENTION OF AIR POLLUTION FROM SHIPS, MARCH 1999


7.11

In the United States it is now a requirement for every tank vessel, whether or not US flagged, wishing to load flammable or combustible cargo in a port where vapor control is required, to be fitted with an approved vapor collection system. The US Coast Guard will endorse the vessel's Certificate of Inspection (US flag) or Certificate of Compliance (non-US flag) after confirmation by the vessel's Classification Society that it meets the requirements of Title 46 CFR part 39 (substantially similar to the requirements of MEPC/Circ.345). Vessels not fitted with a VECS can obtain the relevant endorsement to the COC but will only be able to load and perfoi in ballasting and other operations at ports or facilities where vapor control is not required. These requirements do not effect cargo unloading provided the vessel is kept vapor tight until the vapors remaining in the cargo tanks after unloading can be discharged to a facility ashore.

CAUTION For new and existing vessels which are fitted with a standard inert gas system the cost of modifying same to allow cargo vapor return to shoreside during loading is minimal, all that is generally required is an additional manifold connection, to the inert gas main, on each side of the ship with appropriate shut-off valves and safety devices as specified in the referenced MSC circular. Prudent Owners may, therefore, wish to consider early conversion of their existing tankers to ensure the maximum trading possibilities around the world. However, Owners of smaller tankers, which are less than 20,000 tons deadweight and therefore not bound by the requirement for mandatory installation of an inert gas system, may wish to consider the cost implications of retrofitting an entire vapor return system in order to comply with future VOC controls in known sensitive areas (e.g. certain parts of Northern Europe & the USA) as against including such a system in the specification for all new buildings intended for use in those areas.

9 Fuel Oil Quality

9.1 The operative sections of Regulation 18 after entry into force of the new Annex, as far as the shipowner is concerned, are paragraphs (1) through (6); implementation of paragraphs (7) and (8) are under the direct responsibility of individual Parties to the Protocol of 1997 and are intended to assist in the control of fuel oil quality by regulating the bunker suppliers.

9.3 Regulations 18(1) and 18(2) define the term fuel oil, for the purposes of Annex VI, and indicate those additives, substances and chemical wastes which are allowed or prohibited in fuel oil to be used for combustion purposes on board ships. It should be noted that the wording of Regulation 18(1)(a) has also been adopted, in a recommendatory nature, by the International Standards Organization in their 1996 Specification for Marine Bunker Fuels, ISO 8217, and therefore all fuel oil ordered and supplied to this ISO Specification should already be in compliance with MARPOL VI/18. Regulations 18(3) through 18(5) lay down requirements for the issuance, receipt, maintenance on board and inspection of documentation (bunker delivery notes) pertaining to the chemical and physical properties of fuel oil for use on board ships and are applicable to every ship of 400 gross tonnage or above and every fixed and floating drilling rig and other platfoi uis which have been or will be issued with an International Air Pollution Prevention Certificate. Regulation 18(6) requires that for each bunker delivery, a representative sample of the fuel oil delivered shall be taken and maintained on board until the fuel is substantially consumed but in any case for a minimum period of twelve months. Guidelines for the taking of representative bunker samples have yet to be developed by the IMO but it is expected that they will substantially follow the ISO requirements for manual and automatic sampling contained in ISO 3170 & 3171 respectively, as well as the recommendations

ABS'" GUIDANCE NOTES ON PREVENTION OF AIR POLLUTION FROM SHIPS, MARCH 1999 19


contained in ISO Technical Report No. ISO/TR 13739 entitled "Petroleum Products — Method for specifying practical procedures for the transfer of bunker fuels to ships".

CAUTION Fuel oil can he, and often is ordered to a variety of different specifications ranging Pram the basic density requirement through to full compliance with a national or international standard. However, even with fuel oil ordered to ISO 8217, which is therefore technically in compliance with Regulation 18(1)(a), there are still many instances of engine breakdowns (some resulting in severe mechanical damage) which are attributable to "bad" fuel, not all of which can he blamed on the bunker supplier. Certain litel oils, although supplied within specification, may be incompatible with existing on-hoard bunkers resulting in the Pt-fruition of sludges and/or other damaging mixtures; excessive water content may be the result of leaks from steam heating coils, damaged tank lids or air pipes; and, heated fuel oil tanks are excellent breeding grounds . for microbes (bugs) in fuel oil, especially at the oil/water interface of infrequently drained tanks, which can result in a rapid sludge build-up, filter choking and, in certain cases, severe corrosion within the tank and associated pipework.

Many shipowners already take the wise precaution of having samples of delivered fuel oil analyzed by an independent fuel oil testing laboratory, such as ABS Oil Testing Services, where a fast and efficient service ensures that any likely problems are identified at an early stage and the ship and/or Owner 's technical department notified accordingly; there are also on-hoard testing kits available from various outlets for identifying microbial action and also providing a provisional indication of other contaminants and incompatibility problems.

The bunker delivery note is not intended to replace the above noted services, neither is it intended to be an indication of total fuel oil quality; prudent Owners may therefore wish to continue a regime of independent testing after entry into force of Annex VI thus safe-guarding their ships machinery whilst assuring themselves of the accuracy, or otherwise, of individual bunker delivery notes.

20 ABS GUIDANCE NOTES ON PREVENTION OF AIR POLLUTION FROM SHIPS, MARCH 1999

GUIDANCE NOTES ON PREVENTION OF MR POLLUTION FROM SHIPS

SECTION 4 Compliance With Annex (Including a review of some of the options available)

CONTENTS 1 General 23

3 Chapter 1 - General 23

5 Chapter ll - Survey, Certification and Means of Control 24

7 Chapter Ill - Requirements for Control of Emissions from Ships 25 7.3 Regulation 13 - Nitrogen Oxides 26

7.3.1 General 26

7.3.2 Background 27

7.3.3 Requirements 27

7.3.4 NO, Reduction Options 27

7.3.5 Engine Pre-certification Requirements 28

7.3.6 Clarification of Engine Family, Engine Group and Parent Engine 29

7.3.7 The Technical File 30

7.3.8 Final Certification 31

7.5 Regulation 14 - Sulfur Oxides 32

7.7 Regulation 15 - Volatile Organic Compounds 35

7.9 Regulation 16 - Incinerators 36

7,11 Regulation 17 - Reception Facilities 37

7.13 Regulation 18 - Fuel Oil Quality 38

7.15 Regulation 19 - Offshore Installations 39

ABS`` GUIDANCE NOTES ON PREVENTION OF AIR POLLUTION FROM SHIPS. MARCH 1999 21

GUIDANCE NOTES ON PREVENTION OF AIR POLLUTION

FROM SHIPS

SECTION 4 Compliance With Annex

(Including a review of some of the

options available)

General

The overall content of the new Annex has already been reviewed in section 1 of these Guidance Notes where it was explained that Annex VI chapters 1 & II closely follow the format of MARPOL Annex I with regard to titles and content of the regulations. It has also been pointed out that, unlike the previous three MARPOL Annexes which arc all optional, this Annex has been introduced by means of a Protocol so that, upon entry into force, all Convention ships of Parties to MARPOL 73/78 will require to be issued with an International Air Pollution Prevention Certificate. Section 2 of the Guidance Notes dealt with those aspects of Annex VI and the NO Technical Code which require action to be taken on or after 01 January 2000 whilst section 3 explained the requirements for controlling the other pollutants mentioned in the Annex as well as options for compliance prior to its entry into force. In this section a brief description of the regulations in chapters 1 & 11 of the new Annex is given followed by a review of some of the options available for compliance with chapter III of that Annex.

3 Chapter 1 - General

3.1 Regulations 1 through 4 cover application, definitions, general exceptions and equivalents respectively:

3.1.1

the air pollution Annex will apply to all ships; exemptions from compliance with individual regulations within the Annex, by virtue of ship type, size or equipment application, are indicated in the appropriate regulations;

3.1.2

definitions of terms used within the Annex are included in Regulation 2 but do not include definitions of tei ins used in the NO Technical Code, the latter being found in chapter 1 of

that Code; for ease of reference a complete set of definitions are reproduced as appendix 4 to these Guidance Notes;


Section 4 Compliance With Annex VI

3.1.3

exceptions, as in previous Annexes, are allowable where emissions necessary for the safety of a ship or saving life at sea, or as a result of damage to a ship or its ec. u.:1: ; tv,:n t, renders compliance impracticable; and,

3.1.4

equivalents allow the use of alternative fittings, material, appliance or apparatus provided same are at least as effective as those required by the Annex and providing the Organization is notified accordingly.

5 Chapter II Survey, Certification and Means of Control

5.1 Regulations 5 through 11 cover surveys and inspections, issue of an 1APP Certificate, issue of a certificate by another Government, form of the certificate. duration and validity of the certificate, port State control on operational requirements and detection of violations and enforcement respectively:

5.1.1

all ships of 400 gross tonnage and above, and all fixed and floating drilling rigs and other platforms will be subject to initial, periodic and intermediate surveys as indicated in the regulation, the wording being similar to previous Annexes. For ships of less than 400 gross tonnage the degree of compliance with the Annex is left up to the individual Administrations. There are also the standard requirements regarding use of Recognized Organizations, implementation of unscheduled inspections, action to be taken when condition of equipment does not substantially correspond with particulars of the certificate, maintenance of equipment and Owners responsibilities for reporting accidents and/or defects to the appropriate Authorities;

5,1,2

IAPP Certificates will require to be issued to all ships of 400 gross tonnage or above engaged in international voyages and to all platfoi ms and drilling rigs engaged in voyages to waters under the sovereignty or jurisdiction of other Parties to the 1997 Protocol. Vessels will be expected to comply with this regulation no later than the first drydocking after entry into force of the Annex but in any case no later than 3 years after entry into force;

5.1,3

certificates may be issued by another Government subject to the standard requirements (pertaining to survey, wording of the certificate and the vessel's flag State being a party to the 1997 Protocol) being met;

5.1.4

the form of the certificate is included as an appendix to the Annex and is also required to be completed in either English, French or Spanish if the language used is different to those languages;

5.1.5

the maximum duration of an IAPP Certificate is limited to five years with the proviso that it may be extended by up to 5 months to allow a vessel to return to its home port or to a port where it is to be surveyed. The validity of the certificate is governed, as with other statutory



certificates, by the star dad. requirements for inspections and surveys, confirmation that no

significant unauthorized alterations to equipment and fittings have occurred wick of course, change of flag;

5.1.6

the regulation on port State control on operational requirements is identical to those found in the other• MARPOL Annexes;

5.1.7

additionally, a regulation on detection of violations and enforcement (Regulation 11) is included in the Annex which does not appear in the other Annexes, although similar wording can be found in Article 6 of the 1973 MARPOL Convention. The reason for inclusion of that article in this regulation is to legally differentiate between emission (into the air) and discharge (into the sea). The regulation also references the international law concerning the prevention, reduction, and control of pollution of the marine environment, including the law relating to enforcement and safeguards (United Nations Convention on the Law of the Sea (UNCLOS)) which will apply mutatis tnutandis (with the necessary changes) to the rules and standards set forth in Annex VI,

7 Chapter III - Requirements for Control of Emissions from Ships

7,1 Regulation 12 - Ozone Depleting Substances

7.1.1

Upon entry into force of the Annex all new installations containing ozone depleting substances will be prohibited, existing systems will continue to be acceptable but their life expectancy will obviously depend on availability of replacement gases; those systems with minimal leakage rates may continue to give service for many years but those where leakage is excessive, or where the system is totally or partially discharged, for example for the purposes of fire fighting, will need to be replaced or converted sooner rather than later. The use of HC.FCs in new installations will be permitted until 01 January 2020.

CAUTION Where it is decided to continue to use equipment containing or utilizing CFCs after entry into force of Annex VI, prudent Owners will take steps to ensure that the equipment is properly maintained and gas leakages reduced to an absolute minimum whilst also taking into consideration the likely, availability of replacement gases in the areas of operation of their vessels. As the production of ozone depleting substances is reduced and eventually ceases, the only reliable source of replenishment for existing plant is likely to be an ever dwindling stock of recycled gases available from the Ha lon and CFC International Banking Systems which have been developed to conserve existing stocks of the gases fbr essential users.

WARNING As the global stocks of CFCs are further reduced the second hand market for same will become more lucrative and there is no doubt that, in some areas of the world, ports operating reception facilities for such gases, in accordance with Regulation 17 of Annex VI, will offer recovered refrigerants for direct re-use without any form of reprocessing (despite what the accompanying certification may state). The use of such refrigerants to make good loses through leakages may cause irreversible contamination of an otherwise healthy system resulting in the necessity for premature replacement or upgrading of equipment.

ABS'" GUIDANCE NOTES ON PREVENTION OF AIR POLLUTION FROM SHIPS, MARCH 1999 25


7.1,2

The halons and CFCs which are typically found on board ship are listed in Regulation 2(6), halons being generally associated with fire fighting systems and CFCs with refrigeration, air conditioning systems and the production of certain types of insulation.

7.1.3 Halons are already prohibited for use in new fixed installations by SOLAS II-2/5.3.1 whilst IMO is presently working to extend that ban to portable halon extinguishers as well. Alternatives to baton systems are well documented and readily available, the most common probably being CO2 although high and low pressure water fog systems are gaining

popularity, especially in high speed craft where space and weight are at a premium. Perfluorocarbons (PFCs), which are nearly as effective as halons, are being offered as another alternative but their use is likely to be restricted to specialist vessels, such as submersibles, due to cost and their extremely high global warming potential (GWP). This high GWP prompted the adoption of Conference Resolution No. 7 at the MARPOL Diplomatic Conference which is intended to restrict their application to essential users only.

7.1.4 CFCs, such as RI I, R12, RI13, R1 14 & R115, are to be found in ships refrigeration systems {both cargo and stores refrigeration plants) as well as in independent refrigerated containers and air conditioning systems; one of the most common HCFCs to be found on board ships is R22. Alternative fluids for use in air conditioning and refrigeration systems are well documented and readily available, with new products being marketed at regular intervals. Hydrofluorocarbons (HFCs) such as R23 & R134a are available and suitable for retrofitting into existing systems, these halocarbons contain no chlorine and therefore have a zero ozone depleting potential (ODP) although they do have a GWP and may therefore be subject to controls at some future date. Another alternative being used on some reefer ships is ammonia.

CAUTION When considering retrofitting environmentally friendly refrigerants to existing plant prudent Owners will wish to establish the types of lubricating oil, rubber seals and metals that are used in their plants in order to ensure that new fluids are chemically compatible with those materials. Also, where it is necessary to use a refrigerant that is a blend of fluids rather than a pure fluid, for instance where specific properties are required to be met, care should be taken to ensure availability of that blend in the areas of operation of the vessel, especially when that blend may only be produced by one or two manufacturers.

7.3 Regulation 13 - Nitrogen Oxides

73.1 General The requirements for early compliance with the applicable paragraphs of MARPOL VI/13 and the NO Technical Code have already been discussed in section 2 of these Guidance

Notes where it was pointed out that, upon entry into force of the Annex, engines to which Regulation 13(1) of the Annex applies will require to be surveyed in order to confirm continuing compliance with the emission limits set out in Regulation 13(3)(a) of the Annex prior to issuance of the IAPP Certificate Existing engines (those not included under Regulation 13) will not be subject to any such inspections. Qualifying engines will also have to be kept in compliance with the regulations and this will require to be confirmed during annual, intermediate and renewal surveys for continuing validity of the IAPP Certificate.



7.3.2 Background Nitrogen oxides are formed during the combustion process in internal combustion engines, boilers and gas turbines and are a result of the oxidation of a small percentage of the nitrogen present in air which, with oxygen, comprises 99% of the intake air required for combustion. The nitrogen oxides (NO,) which can be formed include NO & NO, and the amounts are

primarily a function of flame or combustion temperature and, if present, the amount of organic nitrogen available from the fuel. The quantity of produced NO is also a function of

the time the nitrogen and excess oxygen are exposed to high temperatures and, in the case of diesel engines, increased peak pressures, compression ratios and fuel delivery rates will result in an increase in produced NON. Generally speaking, a slow speed engine will produce more

NO than a high speed engine of the same power output hence the different emissions limits

allowed for in the regulations. NO, has an adverse effect on human health and the

environment and contributes to the foiination of acid rain, low level ozone and nutrient enrichment globally.

7.3.3 Requirements

7.3.3(a) Regulation 13 will only apply to engines installed on ships constructed on or after 01 January 2000, new engines installed on existing ships on or after 01 January 2000 or engines which undergo a major conversion, as defined in Regulation 13(2)(a) of Annex VI, on or after that date. Those engines required to comply with the regulation must operate within the undemoted limits:

i) 17.0 g/kWh - for engines with a rated speed of less than 130 rpm;

ii) 45n"•2) g/kWh - for engines with a speed (n) between 130 and 1.999 rpm;

iii) 9.8 g/kWh - for engines with a rated speed of 2000 rpm or greater.

7.3.3(b) The above limits are not particularly onerous, compared to certain land-based controls presently being applied, especially in the USA, and the vast majority of engine manufacturers have already made design and/or operational modifications to their engines in order to comply with the new requirements, although in some cases this has resulted in a modest increase in specific fuel consumption. It should also be noted that there may be national regulations and/or regional requirements for engines to meet more stringent NOx limits than those proposed by MARPOL Annex VI; the Baltic Sea is one such area where agreements between various Baltic States have resulted in some local traffic (ships restricted to Baltic Sea trade only) being encouraged to fit selective catalytic reduction devices (SCRs) and use low sulfur fuel in order to reduce NOx and SOx emissions respectively.

7.3.4 NO Reduction Options

Whilst basic design and/or operational modifications, such as the use of low NO injectors,

retarding injection timing and temperature control of the charge air, will bring the majority of engines into compliance with the NO emission limits prescribed in Annex VI there are a

number of other options available which will result in further reductions in the amount of NO produced by a diesel engine:

7.3.4(a) Exhaust Gas Recirculation (EGR) — as the title suggests a percentage of the exhaust gas is fed back into the inlet manifold and the resultant reduction in 02 concentration in the

combustion zone, coupled with an increase in water and CO2 will give an overall reduction in

produced NO,. Reductions in NO, concentrations of the order of 50% have been reported

with 15% EGR utilization although this is currently restricted to engines operating on high quality distillate fuel due to the problems otherwise associated with the cleaning and cooling of the exhaust gas prior to recirculation, and the disposal of the resultant waste streams.

ABS" GUIDANCE NOTES ON PREVENTION OF AIR POLLUTION FROM SHIPS, MARCH 1999 27


7.3.4(h) Fuel/Water Emulsion — the addition of fresh water to the fuel, and its subsequent emulsification prior to injection into the engine can give typical reductions of produced NO

of 10% for each 10% of water addition. Engine manufacturers have reported successful trials with up to 50% water addition but there can be a fuel consumption penalty of up to 1% increase for each 10% addition of water.

7.3.4(0 Water Injection — as an alternative to fuellwater emulsions fresh water can be directly injected into the engine although this will necessitate additional equipment for the water injection system and is therefore more costly to install. Reductions of produced NO

similar to that expected from emulsions can be expected with typical reported reductions of 20-50%.

Humid Air Motor (HAM) Technique — this method reduces the produced NO by the

addition of wet steam to the engine's combustion air. The method is insensitive to fuel oil quality and engine load and NO reductions of the order of 50-80% have been recorded.

There is no reported fuel consumption penalty and minimal increases in running costs although an initial investment in additional plant will be required.

7.3.4(0 Selective Catalytic Reduction (SCR) — the most efficient method for NO reduction is

still the SCR which will give reductions in produced NO of up to 80-95% when using urea.

This system generally requires the use of low (less than 2%) sulfur fuel and, in addition to initial high capital investment in plant, has increased running costs due to urea consumption and eventual replacement of both oxidizing and reducing catalyst material. Unlike the other options this system is an after-treatment device and is totally independent of the combustion process and therefore potentially suitable for retrofitting to any existing engine.

7.3.5 Engine Pre-certification Requirements

7.3.5(a) For new diesel engines that are required to be in compliance with Regulation 13 of Annex VI it will ultimately be the engine manufacturer's responsibility to ensure that the Administration, or Recognised Organization acting on its behalf, is supplied with sufficient information to be able to assess a particular engine's degree of compliance with the NO

Technical Code. For engines which undergo major conversions it will be for the owner to ensure that the company undertaking that work will provide the necessary information and Technical File in order to satisfy the relevant Annex VI requirements. For the Administration, or Recognized Organization acting on its behalf, the certification process will involve both technical department and field surveyors and, until such time as Annex VI enters into force, a "Statement of Compliance" will be issued in lieu of the Engine International Air pollution Prevention (EIAPP) Certificate in accordance with MEPC/Circ.344 on "Interim Guidelines for the Application of the NO Technical Code" as

approved by the Marine Environment Protection Committee at its 42'° Session in November 1998, a copy of the MEPC Circular is included as appendix 5 to these Guidance Notes.

7.3.5(h) The technical department's involvement in the certification procedure will include an initial approval of an engine Technical File for the parent engine of each engine family or engine group and subsequent confirmation that any engine which is to be installed on a vessel is a bona fide member of an approved engine family or engine group. The initial approval will include, but may not be limited to:

i) a review and acceptance of the range of engine models to be included in an engine family or engine group and the choice of parent engine to represent that family or group;

a review and acceptance of the proposed test bed test procedure;

28 ABS'? GUIDANCE NOTES ON PREVENTION OF AIR POLLUTION FROM SHIPS, MARCH 1999


a. -royal, in principle, of a prelir-Anary copy of the Tel;n:ririe.e 1 File (t1K conents -I are set out at paragraph 2.4.1 of the Code and reproduced in section 7,3.7

below) which would include everything except the copy (- 1. tNe t,ns repor t ;

approval of the final copy of the Technical File, based on the attending surveyor's report of the test bed results, which may include observations and/or recommendations regarding one or more of the items contained in the Technical File, and which may also involve checking the final emissions figure using a standard -NO, calculation procedure.

7.3.5(0 The certification process for an engine which is submitted for approval, based on membership of an existing engine family or group, will require documentary confirmation that the engine is indeed a bona fide member of that family or group, confirmation that the submitted Technical File contains all the required information pertinent to the supplied engine and stamping of the Technical File as an original copy for the particular ship. Notification will also have to be given to the attending Surveyor confirming the review and authorizing issuance of an individual "Statement of Compliance" or EIA.PP Certificate, and Supplement as applicable.

7.3.5(d) The field surveyor's involvement will, apart from attendance for the actual emissions testing, require a confirmatory survey to ensure that the gas analyzers and other testing equipment to be used on the test bed are in accordance with the requirements of the NOx

Technical Code and verification that the parent engine, including all engine parameter adjustments, corresponds to that submitted to the technical department for review and as contained in the preliminary copy of the Technical File.

7.3.5(e) Where the field office surveyor is not visiting a manufacturer's plant on a regular basis (i.e. as part of normal engine classification requirements) and the plant is not acceptably certified in accordance with a recognised quality management system, then conformity of production may be required to be demonstrated for subsequent members of an engine family or group prior to issuance of the relevant certification.

7.3.6 Clarification of Engine Family, Engine Group and Parent Engine

7.3.6(a) The question of engine family versus engine group, extent of membership of the engine family or group and choice of parent engines will, due to the complexity of the concept, undoubtedly generate some disagreements between engine manufacturers. Classification Societies and flag Administrations. It is up to the manufacturer to submit sufficient information and documentary evidence to either substantiate the inclusion of an engine in an existing family or group, or for the definition of a new family or group; historical data is admissible as such evidence and that data is not required to have been witnessed or obtained in the presence of a surveyor, although data obtained from other plants that do not meet the requirements of sections 4.3.10.6 & 4.4.8 of the Code relative to conformity of production will be inadmissible. It is also important to realize that prior to surveyor attendance for a test bed run of any particular parent engine, or the issuance of certification for a new member of an engine family or group (i.e. one that has not already been accepted by the Administration as being a member of a particular family or group), it will be necessary for full details, including preliminary Technical File, to be submitted to the Administration, or Recognized Organization acting on its behalf, for review. It is not intended for surveyors to locally approve engine groups or families, or the parent engines chosen by the manufacturer to represent them. It is to be expected that the family/group concept will become better understood once experience has been gained with application and implementation of the NO Technical Code; however, for the purposes of clarification the following guidance is given:

ABS'' GUIDANCE NOTES ON PREVENTION OF AIR POLLUTION FROM SHIPS, MARCH 1999 29


7.3.6(b) The engine larnily concept may be applied to any series produced engines which, through their design are proven to have similar NO:, emission characteristics, are used as

produced and subsequently not subject to any modifications during installation on board. Where adjustable features are provided (e.g. for balancing cylinder peak pressures and individual cylinder exhaust gas temperatures) they are to be such that no setting, or combination of settings, can adversely affect the engine's NO„ emissions. For engines within

a particular family the applicable characteristics in chapter 4.3.8 of the Code should be common to those engines.

7.3.6(c) The engine group concept may be applied to a smaller series of engines produced for similar engine application and which require minor adjustments and modifications during installation or in service on board. These engines are noi malty large power engines for main propulsion and, for engines within a particular group, the applicable characteristics in chapter 4.3.8 of the Code as well as those parameters and specifications indicated in chapter 4.4.5.2 of the Code should be common to those engines unless specifically indicated otherwise. With regard to the allowable adjustments within an engine group the manufacturer is to provide documentary evidence and/or historical data (e.g. previous test reports) to substantiate that the range of adjustments which are included in the Technical File will permit the engine to operate within the emissions limits set down in MARPOL VI/13(3)(a) and chapter 3 of the NO, Technical Code. It will be up to the attending surveyor at the time

of the parent engine test bed testing to confirm that the allowable adjustments (or combinations of allowable adjustments where more than one parameter is documented as being adjustable) do not result in the total weighted average of NO emissions of that engine

exceeding the permissible limits.

7.3.6(d) The parent engine of an engine family or group must be the engine which has the worst (i.e. highest) NO emission characteristics of that engine family or group, as

documented by the manufacturer and approved by the Administration. For the engine family concept the parent engine must be selected based on criteria contained in chapter 4.3.9.2 of the Code. For the engine group concept the parent engine must be tested with the allowable adjustments set to those positions documented in the Technical File which will give the worst NO emission limits. The engine's actual NO emission value, as documented at section 1.15

of the supplement to the EIAPP Certificate (appendix 1 of the Code) is the value obtained at the time of the test bed testing of the parent engine with the engine adjusted, within the allowable parameters as documented in the Technical File, to give the worst case for NOx emissions. This, in practice, will ensure that the parent engine and all members of the

family or group always operate at or below this worst case scenario and therefore are always in compliance with MARPOL V1J13(3)(a) and chapter 3 of the NO Technical Code.

7.3.7 The Technical File

7.3.7(a) This document is required to be approved by the Administration or Recognised Organization acting on its behalf, and shall as a minimum contain the undernoted information:

identification of those components, settings and operating values of the engine which influence its NO emissions;

ii) identification of the full range of allowable adjustments or alternatives for the components of the engine;

iii) full record of the relevant engine's performance, including the engine's rated speed and rated power;

30 ABS'" GUIDANCE NOTES ON PREVENTION OF AIR POLLUTION FROM SHIPS: MARCH 1999


iv) a system of on-board NO verification procedures to verify compliance with the NO„

emission limits during on-board verification procedures in accordance with chapter 6 of the NO Technical Code;

a copy of the test report required in chapter 5.10 of the NO Technical Code;

if applicable, the designation and restrictions for an engine which is a member of an engine group or engine family;

vii) specifications of those spare parts/components which, when used in the engine, according to those specifications, will result in continued compliance of the engine with the NO emission limits; and,

viii) the EIAPP Certificate, as applicable.

7.3.8 Final Certification

7.3.8(a) For the issuance of the initial IAPP certificate, and at annual, intermediate and renewal surveys thereafter, it will be necessary for the attending surveyor to confirm that each Convention engine's components, settings and operating values have not deviated from the specifications documented in that engine's Technical File. For engine family members it will be sufficient to confirm that any maintenance and/or replacement of NO sensitive

components is in compliance with the Technical File specifications. In the case of engine group members any one of the following three methods may be used except that the direct measurement and monitoring method is not permitted for the initial survey. in eases where the adjustments are found to be outwith the allowable limits they are to be brought back within the limits or the engine re-submitted for testing to confirm that it remains in compliance with the NO„ Technical Code.

7.3,8(b) Engine parameter check method, in accordance with chapter 6.2 of the NO

Technical Code, to verify that an engine's components, settings and operating values have not deviated from the specifications in the engine's Technical File. in practice this method will be the preferred option for the majority of engine manufacturers and ship owners. It is up to the engine manufacturer to ensure that such checks can be carried out without undue delay to the vessel and, where specialist tools and/or equipment are required, that they are supplied with the engine and with adequate instructions for their use. This method is likely to consist of a visual examination for the initial survey with visual examination and/or document check at subsequent surveys. A sample check list for the visual examination is included as appendix 6 to these Guidance Notes and the document check would consist of a review of the entries in the "Record Book of Engine Parameters" which is the document for recording all parameter changes, including components and engine settings, which may influence the NO,

emission of the engine.

7.3.8(c) Simplified measurement method, in accordance with chapter 6.3 of the NO

Technical Code, for on-board confirmation tests and periodical and intermediate surveys when required. As the title suggests this method is a simplified version of the full test bed methodology and there are certain allowances which may be applied in calculating the final emissions figures to take account of possible deviations in instrument accuracy and the presence of nitrogen in the fuel. Further details can be found in chapter 6.3.11 of the NO

Technical Code. Due to the difficulty in carrying out such measurements, and the logistics of transporting laboratory type equipment and calibration gases to locations remote from their point of origin, this method :is only likely to be used for special cases.

ABS''' GUIDANCE NOTES ON PREVENTION OF AIR POLLUTION FROM SHIPS, MARCH 1999 31

Section 4 Compliance ih Annex Vi

. o i re: ?nca:?vement monkr iod n accort , sections of che.pt.ers 2 & 5 of the NO Technical Code. 1 his

measuremcn:.fluoniayring

iJ the quantity of injected urea, and its strength, for SCR type systems;

ii) the quantity of water injected per unit fuel for water injection systems;

iii) the quantity of water mixed per unit fuel for water/fuel emulsion systems;

the concentrations of NON, CO2, CO & 07 in the exhaust gas stream by means of gas

monitoring equipment.

Note: The use of gas monitoring equipment will be dependent on the IMO agreeing guidelines for the certification of such equipment and this item is further discussed in section 5.5.5 of these Guidance Notes.

CAUTION Prudent Owners, prior to ordering new engines subject to the NOx Technical Code, may wish to review the manufacturer's proposals jar demonstrating compliance with the 1VOx emission limits on board to ensure that the method(s) set out in the Technical File are both practical and suited to their particular mode of operation. Prudent Owners may also wish to take into consideration financial incentives which are available to ships visiting certain parts of the world where reductions in port lees may he offered in return for ships complying with more stringent engine emission limits, fir-instance by the installation and use of one of the Nay reduction options noted earlier in se.ctio; 7.3.4 .

7.5 Regulation 14 - Sulfur Oxides

7.5.1

Unlike the previous regulation the emission of sulfur oxides resulting from the combustion of all fuel oil supplied for use on board ships will be subject to controls once Annex VI enters into force. However, whilst there may be a period of grace of up to three years after entry into force of the Annex before a ship is required to be issued with an IAPP Certificate (MARPOL V1/6(2) refers), the period allowed under Regulation 14(7) for compliance with SO, Emission Control Area (SO\ECA) emissions is limited to 12 months from the date of

entry into force of the Protocol. This 12 month period of grace will also apply to any amendments to the Protocol designating a specific SO,ECA under Regulation 14(3)(b) of the

Annex.

7.5.2

The adoption of a relatively high global sulfur cap in Regulation 14(1), i.e. 4.5% rn/m will have little or no effect on shipping as the International Standards Organization have already indicated that they will align the ISO 8217 specification (the industry standard), presently set at 5.0% for the majority of residual fuel oil grades, with the IMO requirements at its next revision. The majority of shipping will therefore have to do no more than to ensure that bunker delivery notes and fuel oil samples are supplied and maintained on board as per the applicable parts of Regulation :18 which have already been dealt with in section 3 and are further explained later in this section.



en ships which require to trade within a SO.,,ECA will have L. mee.t the more

emission requirements laid down in Regulation 14(4) and the lengm of time that ana l-

ship spends in such an area is likely to dictate the means adopted by Owners for com?li

7.5.3(0) Primag Control. The use of a low sulfur (less than 1.5% m/m) fuel, as per Regulation 14(4)(a) will limit the formation of the pollutant to, or below, the maximum permitted i.e. 6.0 g SO,/kWh: compliance with the regulation can be demonstrated by

appropriate entries in the ship's official log book stating when and where the ship changed over to using low sulfur fuel and the bunker tank ullages at that time. It will be necessary to effect the change-over to the lower sulfur fuel in sufficient time to ensure that the ship's fuel oil system is totally flushed of all fuels containing more than l.5% m/m sulfur content prior to entry into a SO,ECA. Whilst low sulfur fuel oil may be readily available in certain parts

of the world, for example in Northern Europe where there is a requirement for large quantities of sulfur controlled oil fuels from Utilities and other shore based users, and Where a proportion of the crude oil feed stock to refineries tends to be low in sulfur anyway, it is likely that many ships will opt to burn gas oil which is traditionally supplied with a maximum sulfur content of 0.5% m/m and, in many cases, less than 0.2% m/rri.

7.5.3(h) Secondary Control. This will effectively be some form of exhaust gas cleaning system, or other technological method which is "verifiable and enforceable", and will require to be approved by the Administration based on guidelines to be developed by the Organization. There are at present no approved guidelines for exhaust gas cleaning systems although the Design and Equipment Sub-Committee have been given a target date for completion of such guidelines by 2003 only if there is a demonstrable need for same. Present day technology as applied to the design of scrubbers for use in inert gas installations is likely to be the way forward in the medium term although such a scrubber plant may be prohibitively large if required to handle the full exhaust gas flow from say a 20 MW slow speed diesel engine which can amount to some 140 tonnes/hr. The possibility of part flow systems are further discussed in section 5.5.4 of these Guidance Notes. The other main problem with a scrubber unit is that it discharges a "waste stream", which has the potential of being regulated under Regulation 14(4)(b), and that waste stream is also likely to be acidic in nature requiring additional measures to be taken to avoid corrosion to the pipework and hull penetration of the overboard discharge.

7.5.3

7.5.4

As has already been stated, a ship's trading patterns and, to a certain extent, engine type will determine the options for complying with the emission limits in SO,ECAs once the Annex

has entered into force. Those ships powered by gas turbines, and those with diesel engines which are permanently operated on gas oil will not be affected because of the low sulfur content of the type of fuels used. Those ships permanently operating in SO,ECAs will

likewise be unaffected because the only fuel available for them to purchase will already have a low (less than 1.5% rn/m) sulfur content whilst those ships which never enter a SO,ECA

will not be subject to the stricter emission limits and will also be unaffected. The ships which may encounter problems are those which trade in and out of the emission control areas and which predominantly operate on "standard" (i.e. greater than 1.5% mlin sulfur content) marine bunkers for it is these ships which will require to switch fuels or engage an exhaust gas cleaning system prior to entry into the SO,ECA.

ABS' GUIDANCE NOTES ON PREVENTION OF AR POLLUTION FROM SHIPS, MARCH 1999 33


Leaving aside the use of exhaust gas cleaning systems. as these are presently not an option for the reasons given in section 7.5.3(b) above, there are a number of considerations to be taken into account by an Owner when faced with operating in and out of an emission control area; these considerations will influence the design of new buildings (see also the Caution at the end of section 3.5 of these Guidance Notes) as well as the operation of existing shipping. The main consideration will be the size of the emission control area(s) and their location relative to major shipping routes and/or regular ports of call; at the time of adoption of Annex VI there was only one identifiable SOxECA, namely the Baltic Sea. The North Sea States

have, however, already made a preliminary submission to the IMO for the North Sea, including the English Channel, to be considered as an emission control area and, if agreed by the MEPC, it is likely that this will be accepted under the MARPOL amendment procedure and become effective upon entry into force of the new Annex. There is also a possibility that the North Sea SOx ECA could be extended to the west of the United Kingdom at some future

date to protect vulnerable areas of land on the west coast of the UK and Ireland.

7.5.5

7.5.6

For those owners who find themselves faced with part operation within a SO, emission

control area and who normally operate their engines on fuel oil having a sulfur content greater than 1.5% tritm it will be necessary to carry more than one grade of fuel oil so that compliance with the stricter emission limits can be accomplished by fuel switching. This is a somewhat similar procedure to that which used to occur in the early days of diesel propulsion where it was common practice to burn gas oil while manoeuvring and standard bunkers when "full away"; unfortunately modem ship design has tended to ignore the traditional multiple fuel tank configurations, except in specialist vessels. The following aspects will therefore need to be addressed for ships intending to carry out fuel switching operations:

7.5.6(a) provision for a sufficient quantity of low sulfur fuel oil to be stored on board for operation in the emission control area; this fuel will need to be segregated from the other fuels used for combustion and may require modifications to oil storage arrangements and fuel distribution systems on some existing vessels;

7.5.6(b) provision of an adequate supply of low sulfur fuel oil being available on board prior to entry into an emission control area; this may require the diversion of a ship to a port outside of the area in order to take on suitable bunkers, particularly if the ship does not normally trade in the SOxECA and/or has come from an area where suitable fuel is not

available;

7.5.6(c) consideration of operational and safety aspects such as:

the possibility of incompatibility between high and low sulfur fuels;

the possibility and likely effects of lighter fuels washing out accumulated deposits in the system;

the effect of lower viscosity fuels on worn fuel oil injection components;

changes in combustion performance; and,

the effects of operating a ship's engines for a prolonged period of time with a particular level of sulfur in fuel substantially different to that normally used; this will require conditioning of the tube oil in order to adjust its Total Base Number (TBN) and in extreme cases a complete oil change may be required.

34 ABSF GUIDANCE NOTES ON PREVENTION OF AIR POLLUTION FROM SHIPS, MARCH 1999


7.5.7

Because of the variety of options available for addressing aspects relative to fuel switi., it will be necessary to assess the cost implications associated with each before deciding on the most appropriate method of compliance for individual vessels. The feasibility of carrying out modifications to older ships will also depend on when the new regulations are likely to enter into force. In order to carry out an adequate assessment, information on the availability of low sulfur fuels in various parts of the world, including relative costs, will need to be made available; the cost of carrying out structural modifications to existing fuel oil tank arrangements and duplication of at least some of the distribution piping and equipment will have to be investigated; and, the effects of loss of primary bunker space on a vessels operational range, because of partitioning and/or isolation of existing tanks for use with low sulfur fuel, will need to be considered.

CAUTION In order to avoid some of the problems associated with fuel oil switching, prudent Owners may wish to avail themselves of the services of a fuel oil testing company, such as ABS Oil Testing Services, who will he able to confirm the compatibility of oil fuels which will need to he mixed as well as the sulfur content of low sulfur fuels taken on board to ensure that they are in accordance with the information contained in the bunker delivery note required by MARPOL VI/18(3).

With regard to lubricating oil, prudent Owners will also wish to ensure that ships staff are aware of the potential problems of operating an engine lbr prolonged periods using a fuel oil which has a sulfur content significantly lower or higher than that which has been in use. Increased frequency of testing may he recommended by the Owner to monitor the condition of the oil thus avoiding possible costly repairs resulting from damage caused by increased contamination of the oil by fuel and the products of combustion.

WARNING Until such time as the Annex enters into force it is not known how policing of SO Emission Control Areas will be carried out although coastal States

bordering a SOxECA are likely to be more vigilant than those remote from it. Whilst the first line of control will, in the majority of cases, be examination of the bunker delivery notes and log book entries for fuel switching, or examination of exhaust gas cleaning system operational records when such equipment finally becomes available, any doubts on the part of the PSC Inspector as to the accuracy of such records could trigger a more detailed on-board investigation. Such an investigation may include verification of the sulfur content offuel oil, both as delivered and as used, and may lead to delays in a ship's departure while laboratory samples are analyzed. Owners should also be aware that equipment for remote sensing of exhaust gas plumes is available and already in use in some Scandinavian Ports; such equipment is capable of being operated day or night and readings in the region of 400 ppm SO2 concentration would indicate use of a higher sulfur content fuel and also likely to trigger the more detailed on-board inspection noted above.

7.7 Regulation 15 - Volatile Organic Compounds

7.7.1

As has already been explained in section 3.7 of these Guidance Notes, the control of VOCs is only applicable to gas, chemical and oil tankers operating in ports or terminals under the jurisdiction of Parties to the 1997 Protocol who have signified their intention, to the IMO, to implement such controls. It has also been explained that the operation of FPSOs and FSUs,

ABS' GUIDANCE NOTES ON PREVENTION OF AIR POLLUTION FROM SHIPS MARCH 1999 35

Secilon 4 Compliance With Annex VI . .

when loading si-ruttiz: tanker.. Cqfn1.aiDS a grey area and, until such time as the t.F, .. clarifies the role of ',inch v,i::ssels in relation to MARPOL in general, it will be to individual Adminktration:s to advise the IMO whether they conside, s opciraio:Ri., are under their

indiction to be within the remit of iP e]..juiii1ion 15 or nut. HoweI, absence of approved international guidelines, for equipment and operational procedures to control VOCs which are produced as a result of ship to ship transfers, is likely to preclude such a decision in many areas of the world in the medium term although ABS has developed equipment requirements and a Record notation for lightering operations (see section 7.7.3 below).

7.7.2

Ships which are required to be fitted with a vapor collection system must comply with the applicable requirements of MSC/Circ.585 on Standards for Vapour Emission Control Systems, as must operators of ports and terminals when installing vapor emission control equipment intended for collecting VOCs from tankers. The regulation allows for a period of grace of up to 3 years, for ships visiting ports or terminals which have declared an intention to control VOC emissions, before the vapor collection system becomes mandatory. However, experience has already shown that some refineries, where equipment is already fitted, are not waiting for entry into force of the new Annex but are imposing their own arbitrary period of grace after which non-compliant ships will be excluded at the chartering stage. In order to assist Owners in planning for early implementation of VOC emission controls the MEPC, at its 42' session in 'November 1998, approved 'MEPC/Circ.345 on "Notification to the Organization on Ports or Terminals where volatile organic compounds (VOCs) are to be Regulated", a copy of which is included at appendix 2 to these Guidance Notes. For further details see also section 7 of these Guidance Notes.

7.7.3

ABS has, since 199.1, been certifying vapor emission control systems in accordance with their "Guide for Cargo Vapor Emission Control Systems on board Tank Vessels". Installations meeting the requirements of this Guide are distinguished in the Record by the notation "VEC" for normal loading operations and "VEC-L" for lightering operations. VECS equipment on tank vessels certified in accordance with section 2 of that Guide and distinguished by the notation "VEC" will also satisfy the requirements of MSC/Circ.585 although an additional review of cargo operations manuals, including the inert gas manual, will be required to confirm that they contain information on:

7.7.30) sequential shutdown of onshore pumps and/or valves, and of ship's valves (for cargo overfill protection);

7.7.3(h) operational procedures; and,

7.7.30 transfer procedures.

Further information can be obtained from any regional or local ABS Technical Office.

7.9 Regulation 16 - Incinerators

7.9.1

As has already been explained in section 2.5 of these Guidance Notes, all incinerators installed on board ships after 01 January 2000 will require to be type approved in accordance with Resolution MEPC 76(40) on "Standard Specification for Shipboard Incinerators". Upon entry into force of the new Annex, all such incinerators will also have to be operated within the following limits and documented as such:

7.9.1(a) O, in combustion chamber: 6 -

36 ABS'"' GUIDANCE NOTES ON PREVENTION OF AIR POLLUTION FROM SHIPS, MARCH 1999


(b) CO in flue gas maximum mieragi.:: 200 mg/MJ

7.9. ( c) Soot number maximum average: BACFIARACH 3 or R1NGELMAN 1 i.e. 20% opacity. (A higher soot number is acceptable only during very short periods such as starting up)

7.9.1(d) Unburned components in ash residues: Max 10% by weight

7.9.10 Combustion chamber flue gas outlet temperature range: 850-1200°C

Note 1: Flue gas outlet temperature and 0, content should be measured during the

combustion period, and not during the preheating or cooling periods.

Note 2: A high temperature in the actual combustion chamber/zone is an absolute requirement in order to obtain a complete and smoke free incineration, including that of plastic and other synthetic materials while minimising dioxins, VOCs and other emissions.

7.9.2 Operators of such incinerators will also have to be trained in their use taking into consideration the contents of the mandatory operations manual required by Regulation 16(7) to ensure that the incinerators are maintained and operated within the specified limits.

7.9.3 Existing incinerators installed on board ships prior to 01 January 2000 may still be used after entry into force of the Annex although the incineration of polyvinyl chlorides (PVCs) in them will be prohibited by Regulation 16(6).

7.9.4 As with the NO regulation, until such time as the Annex enters into force Regulation 16 is

unenforceable; this means that although an incinerator may have been type approved in accordance with MEPC 76(40) at the time of its manufacture, evidence of its operation within the prescribed limits and operator training may not be required until such time as the initial survey for issuance of the IAPPC is carried out.

CAUTION In order to avoid possible problems and/or delays with the issuance of the JAPPC, prudent Owners should ensure that incineration equipment installed on board ship on or after 01 January 2000 is maintained in a condition which allows operation within the prescribed limits at all times: operators should therefire be suitably trained and a copy of the manufacturer's operating manual made available on board, all prior to entry into farce of the new Annex. One method of ensuring the foregoing is to incorporate incinerator operational requirements into the vessel's SKIS/ISM documentation.

7.11 Regulation 17 - Reception Facilities

7.1 1 .1 This regulation has little impact on the Owner or Operator of ships in as much as the onus for providing suitable reception facilities for ozone depleting substances, equipment containing such substances and residues (waste streams) from exhaust gas cleaning systems (where these are not permitted to be discharged under Regulation 14(4)(b)) lies with the Government of each Party to the Protocol of 1997 (i.e. signatories to MARPOL Annex. VI); the availability of such facilities should not cause undue delay to ships.



7.11.2

Whilst the onus for providing reception facilities ties with individual contracting Governments it is the ship operator's responsibility to ensure that such "waste" is delivered to those facilities and where same are either not available, or alleged to be inadequate, they should be reported by the vessel, to its flag Administration, for onward transmission to the IMO.

CAUTION Prudent ship operators will ensure, prior to carrying out essential maintenance on plant containing ozone depleting substances, including replacement of same, that adequate reception facilities' are available at the intended repair port. Failure to do so, after entry into force of the Annex, could result in action being taken against the ship by its flag Administration should evidence suggest that ozone depleting substances were discharged to the atmosphere whilst still on board the ship, even if the discharge was caused by the action of shoreside repair personnel.

7.13 Regulation 18 - Fuel Oil Quality

7.13,1

As has been previously indicated, after entry into force of the new Annex the operative sections of Regulation 18, as far as the shipowner is concerned, are paragraphs (1) through (6); implementation of paragraphs (7) and (8) are under the direct responsibility of individual Parties to the Protocol of 1997.

7.13.2

Owners of Convention ships need, therefore, do no more than to:

7.13.2(a) ensure that their ships are bunkered with fuel oil in accordance with ISO 8217 or equivalent;

7.13.2(b) maintain properly completed bunker delivery notes for a minimum period of 3 years;

7./3.20 maintain properly certified fuel oil samples for a minimum period of 1 year or until the fuel is substantially consumed, whichever is the longer; and,

7.13.2(d) make available copies of bunker delivery notes, when required by the PSC authority, in a timely manner to avoid undue delays to ships.

CAUTION Many shipowners already take the wise precaution of having samples of delivered fuel oil analyzed by an independent fuel oil testing laboratory, such as ABS Oil Testing Services, where a fast and efficient service is readily available; the bunker delivery note is not intended to replace this service, neither is it intended to be an indication of total fuel oil quality. Prudent Owners may therefore wish to continue a regime of independent testing after entry into force of Annex VI thus safe-guarding the ship's machinery whilst assuring themselves of the accuracy, or otherwise, of individual bunker delivery notes.


Section 4 Compliance With Annex Vi

7.15 Regulation 19 - Offshore Installations

7.15.1

As with the equivalent Regulation 21 in MARPOL Annex I, Regulation 19 exempts, from the provisions of Annex VI, emissions directly arising from the exploration, exploitation and associated offshore processing of sea-bed mineral resources. Such emissions may include, but not be limited to:

7.15.1(a) flaring of hydrocarbons both during well testing and arising from well upset conditions;

7. /5. /(b) burning of cuttings, muds and/or well stimulation fluids during well completion and testing;

7.15.1(c) release of gases and volatile compounds entrained in drilling fluids and cuttings;

7.15.1(d) release of gases and volatile compounds during the treatment, handling or storage of sea-bed minerals; and,

7.15.1(e) NO, emissions from diesel engines used solely for the exploration, exploitation and

associated offshore processing of sea-bed mineral resources.

7.15.2

With regard to NOx emissions, only those engines which are used exclusively for

exploration, exploitation and associated offshore processing of sea-bed mineral resources will be exempted, for example dedicated mud or cement pumps. Diesel engines which are connected to a common distribution system supplying hotel services as well as drilling equipment will not be exempt, neither will those engines used to power cranes. In practice this will make little difference to the offshore industry as it is highly unlikely that engine manufacturers will continue to produce engines which do not meet the .NOx limits imposed

by either Annex VI, or even stricter shoreside legislation. Whilst it will be up to individual Administrations to decide on how temporarily installed ri Party equipment containing diesel engines is to be dealt with on platforms and drilling rigs, after entry into force of the new Annex, it is assumed that the vast majority of such equipment will be classed as essential drilling equipment and therefore exempted u.nder Regulation 19(2)(d). To do otherwise would lead to administrative problems with regard to the unit's LAPP Certificate which would need to be continually updated as temporary equipment was placed on board or removed.

CAUTION Because of the highly specialized nature of certain drilling related equipment it is not uncommon fir 3r`i Party (temporary) equipment, such as diesel driven cement pumps, to be installed on board platforms or drilling rigs for long periods of time, thus becoming semi permanent, and in some cases permanent fixtures. Prudent Owners/Operators may therefore wish to confirm with their own flag Administrations any special requirements they may have in such cases and equally, for mobile units, the requirements of coastal States in which individual units are intended to be operated should be ascertained. Such information can be obtained directly from many Administrations or through the local/regional ABS Technical Office.


GUIDANCE NOTES ON


SECTION 5 The Future

CONTENTS

General 43

3 Future emission controls 43 3.1.1 Carbon monoxide (CO) emissions 44

3.1.2 Hydrocarbon (HC) emissions 44

3.1.3 Particulate Matter (PM) emissions 44

3.1.4 CO-) emissions 44

3.1.5 Smoke emissions 44

5 Future Technology 45 5.1 General 45

5.3 VOCs as an Alternative Fuel 45

5.5 Exhaust Gas Monitoring Systems 46

5.5.1 General 46

5.5.2 Equipment Availability and Use 46

5.5.3 Types of Systems 47

5.5.4 Application to Shipping 48

AB GUIDANCE NOTES ON PREVENTION OF AIR POLLUTION FROM SHIPS, MARCH 1999 41

GUIDANCE NOTES ON


SECTION 5 The Future

General

As was the case with the implementation of the earliest legislation for the control of land-based air pollution, Annex VI can be considered but a foundation stone for the introduction of ever more stringent controls on emissions from shipping. Whilst the Air Pollution Annex may not enter into force for a number of years, there will be an increasing number of regional agreements and/or local legislation which will directly affect shipping plying its trade in those areas. We are already witnessing a number of American and European ports insisting on oil tankers being fitted with suitable vapor collection systems for the purpose of controlling emissions of VOCs; certain European ports are offering financial incentives for ships (particularly local trade) to voluntarily control emissions of NO & SO, indeed, some flag States have already indicated that such controls may

become mandatory; controls on the type of incinerators and their use are already in force in a number of particularly sensitive ports; and, of course, offshore installations are subject to a plethora of coastal State restrictions in a number of regions with respect to various types of marine and atmospheric pollution.

3 Future emission controls

3.1 As has been previously mentioned the single largest contributor to atmospheric pollution is the continuing use of fossil fuels and it is this aspect, particularly the use of diesel engines and other combustion machinery (e.g. boilers and gas turbines) for main propulsion and auxiliary services, which is likely to be the focus of further legislation in the future. NO & SO, limits have already

been discussed in previous sections but there is a growing consensus, especially within certain parts of Europe, that NO emission limits should be further reduced, and possibly even applied to existing

engines, once technology permits the modification of such engines without undue financial burden to the owners or operators of affected shipping. To further enforce this view the M.ARPOL Diplomatic Conference which adopted the new Annex also adopted Conference Resolution 3 on "Review of Nitrogen Oxide Limits" which invites the MEPC to review the NO, limits at 5 yearly intervals after

entry into force of the Annex. The use of more "environmentally friendly" bunker fuels is being encouraged in some areas by regional restrictions on the sale of high sulfur fuel which is also likely to reduce emissions of SO, in and around those regions prior to entry into force of the new Annex.

Other pollutants from diesel engines and other combustion sources which may be considered in the future are:

ABS'" GUIDANCE NOTES ON PREVENTION OF AIR POLLUTION FROM SHIPS: MARCH 1999 43

The Fu u

3.1.1 Carbon monoxide (CO) emissions

These are relatively low for marine diesel typical values in the order of 2.0 g/kWh with even lower values being recorded ror 'Poi and as turbines. Carbon :Donoxide tends to be a localized problem with concentrations peaking in and around pen areas : to heavy traffic and prior to its oxidation to CO,.

3.1.2 Hydrocarbon (HC) emissions

Typically less than 1.0 g/kWh unless the diesel engine is operating at very low (less than 20%) load in which case levels can be dramatically increased. .HC emissions, along with NO and VOCs, are responsible for the formation of low level ozone and photochemical

smog, both of which can cause respiratory problems affecting human health. Unlike NO

emissions, which will not materially increase over the life of an engine, .HC emissions can be seriously affected by the physical condition of an engine and are particularly sensitive to the standard and frequency of maintenance carried out.

3,1.3 Particulate Matter (PM) emissions

The quantity of these emissions depend, as with HC emissions, on the quality of engine maintenance with PM emissions increasing as the level of maintenance decreases; the level of emissions also depends on the type of fuel used with fuel oil typically giving around 1.5 g/kWh and gas oil 0,2 g/kWh of PM emissions. Particulate matter consists of, but is not limited to, elemental carbon (soot), sulphates, nitrates, ash minerals, heavy metals and partially combusted hydrocarbon components of both fuel and lubricating oils; as sulphates and sulphate bound water can account for in excess of 50% of PM. emissions the use of low sulfur fuels can dramatically reduce those emissions.

3.1.4 CO, emissions

Of all the emissions discussed to date CO., is likely to be the next target for the

environmental lobby who are keen to reduce greenhouse gas emissions across the board. It is a scientific fact that for every tonne of fuel oil consumed approximately 3 tonnes of CO, is

produced and, as the carbon content of marine fuel oil is reasonably constant, the only way to reduce CO, emissions from ships is to burn less fuel oil. The Diplomatic Conference which

adopted the new Annex on air pollution also recognised the continuing problems associated with emissions of greenhouse gases and agreed, by means of Conference Resolution No. 8, to co-operate with the UNFCCC by undertaking a study of CO, emissions from ships for the

purpose of establishing the amount and relative percentage of CO2 emissions from ships as

part of the global inventory of CO, emissions.

3.1.5 Smoke emissions

The only form of legislation to affect shipping for many years has been that concerned with the emission of dark and black smoke; this form of legislation is to be found in ports and harbours in many areas of the world and is normally applied by a remote observer comparing visible emissions against a standard smoke chart. Such controls have always been imposed nationally rather than internationally and have been enacted under various guises such as Clean Air Acts, Control of Smoke Pollution and Environmental Protection legislation. As coastal authorities in many parts of the world are being increasingly tasked with controlling and improving air quality in and around ports under their jurisdiction, the visible fraction of the exhaust gas streams from ships engines, whether black smoke (soot particles), blue smoke (products of incomplete combustion of fuel and lubricating oils) or white smoke (condensed water and/or vaporized fuel), is likely to become another source of funding for the improvement of local air quality.

44 ASS GUIDANCE NOTES ON PREVENTION OF AIR POLLUTION FROM SHIPS, MARCH 1999

Section 5 The Future

5 Future Technology

5.1 General

5.1.1

We have already discussed the continuing quest, by manufacturers of refrigerants and fire fighting gases, to develop more environmentally friendly replacements for ozone depleting substances and, technologically, there is little more that can be done to comply with Regulation 12 of Annex VI.

5.1.2

Regulations 13 & 14 on the control of NO and SO, respectively refer to "other technological

methods" thus leaving the way open for the acceptance of future, possibly novel, methods of emission abatement; present operational research includes, but is not limited to:

5.1.2(a) additional firing chambers for gas turbines;

5.1.2(h) infusion of water mist with fuel & subsequent gas scrubbing units for slow speed diesels;

5. /.2(c) use of alternative fuels and duel fuel engines (see also 5.3 below); and,

5.1.2(0 alternative power sources (fuel cells).

5.1.3

Regulation 16(10) leaves the way open for the development, installation and operation of other shipboard thermal waste devices as an alternative to incinerators whilst continuing improvements in fuel oil treatment devices will undoubtedly lead to improved combustion and less sludge per tonne of fuel used.

5,1.4

Since the development of alternative devices for the control of emissions of certain pollutants will require measurement of those pollutants, the area most likely to be the focus of medium term research, development and application is the use of exhaust gas monitoring equipment for that measurement and subsequent control of both primary and secondary emissions abatement equipment. The use of gas monitors for the optimisation of engine combustion efficiency, by the input of emissions data to the electronic engine management system, is another area where such equipment is likely to find increasing favour within the marine industry. Exhaust gas monitoring systems are further discussed in 5.5 below.

5.3 VOCs as an Alternative Fuel

5.3,1

We have already discussed, in section 4.7.7 of these Guidance Notes, the standard method for control of VOC emissions utilised during tanker loading operations and how such procedures are not internationally recognised for use with FPSOs when engaged in loading shuttle tankers in the field. However, a research project presently being jointly undertaken by a northern European engine manufacturer and Norwegian oil company is examining the use of VOCs on crude oil shuttle tankers as an alternative fuel source; this concept, whilst considered a new approach for VOC abatement, has in fact been used for many years in utilising the boil off from liquid methane cargoes for combustion purposes in marine boilers of steam turbine driven LNG gas carriers.


The Future

5.3.2 The new concept involves the collection and storage of the more readily condensable VOCs (mainly propane, butanes (LPG) and higher hydrocarbons) which are then stored in either an insulated tank at atmospheric pressure and at low temperature (-45°C), or in a pressurised tank (10 bar gauge) and at atmospheric temperature. The lighter components (methane and ethane) given off by the crude oil will still be vented to atmosphere although a future development is expected to involve the capture of these gases for use as fuel as well. The liquid VOCs are finally delivered to the engine, via a suitable pump, at high pressure (400 bar) and injected directly into the combustion chamber immediately after the injection of a small quantity of pilot oil, which is required to maintain stable combustion. Claims of fuel oil savings of up to 90%, depending on composition and availability of VOCs as well as the ship's sailing schedule, coupled with reductions in emissions of NOx (20-30%), SOx (50-

90%), particulates (50-90%) and some CO2 are likely to make such a system attractive to

owners of shuttle tankers, FPSOs and possibly VLCCs.

5.5 Exhaust Gas Monitoring Systems

5.5.1 General 5.5.1(a) It has already been pointed out that. whilst the option for various types of monitoring is included in chapter 6 of the NOx Technical Code, as far as exhaust gas monitoring is

concerned there are no systems presently available which are approved for use on board ship; the reason for this is that there is, at present, no internationally agreed marine specification for shipboard exhaust gas monitoring systems. The Design and Equipment (DE) Sub-Committee of the IMO have been tasked by the MEPC to develop suitable Guidelines for the certification of such equipment as a high priority item and work is scheduled to commence in March 1999 with completion by 2003.

5.5.1(b) The gas monitoring equipment market for land-based sources of air pollution is now considered to have reached maturity, particularly with regard to stack gas analysis. This is in no small way due to the pressures that have been placed upon industry ashore to demonstrate compliance with increasingly stringent emission standards. In general, gas measuring technology has been driven by demands for greater sensitivity, real-time monitoring and multi-parameter systems with the equipment being designed to meet applicable national and international standards in order to ensure as wide a market as possible. A number of National Administrations operate mandatory monitoring equipment certification schemes which are designed to demonstrate the performance and robustness of the equipment so that potential customers can be confident that the equipment is fit for its intended purpose. Given the proven use of monitoring equipment in the chemical, cement manufacturing, waste incineration and power generation industries, it would seem reasonable to assume that the marine environment will not pose any significant additional operational problems.

5.5.2 Equipment Availability and Use 5.5.2(a) Equipment already available for onshore exhaust gas monitoring includes both fixed and portable units, each being capable of detecting, analyzing and recording single or multiple gases depending on the level of sophistication of the equipment. Portable units are, by definition, not suited to continuous monitoring and are used ashore mainly for spot checks by enforcement agencies, plant maintenance personnel and operators of small or multi-stack plants where the fitting of permanent monitoring equipment is not deemed cost effective. Fixed, or permanently installed monitoring equipment, especially on larger plants, can be configured to monitor and control the levels of a number of pollutants at various stages throughout the process with records of atmospheric discharges being presented in a variety of ways dependent upon, for example, plant operation and national discharge limits.


Section 5 The Future

Manufacturers' quoted system specifications vary depending on the type of analyser utilised and the medium being measured, but will include operational temperature ranges as well as figures for accuracy and linearity, cross sensitivity, zero and span drift, repeatability and response time. Many of the monitoring systems now available are PC based and have the capability of displaying measurements in parts per million (ppm), ing/m3, mg/kWh or simply as a percentage. Some of the latest optical radiation systems incorporate on-line calibration verification using sealed certified gas cells and filters enabling both zero and span checks to be made automatically, thus removing the need to carry a range of calibration gases.

5.5.2(b) As to the use to which the various types of monitoring systems may be put there is no need to look further than the normal day-to-day activities of such industries as power generation, waste incineration, mineral wool production, cement manufacturing, chemical manufacturing and refinement, fertilizer production, national air quality measurements and aircraft emissions measurements in airports. Of relative interest to the marine industry is the use of monitors in the power generation and waste incineration industries. In the power industry, where selective catalytic reduction (SCR) is employed, emissions are typically monitored for nitric oxide (NO), nitrogen dioxide (NO2) and ammonia (NH3); sulfur dioxide (SO2) and water vapor may also be measured before and after scrubbers and processes

controlling lime dosage. In waste incineration plants, as well as monitoring the emissions and processes noted earlier, hydrogen chloride (HCt), mercury (Hg), hydrogen fluoride (HF) and carbon dioxide (CO2 ) may also be required to be monitored for emission control purposes.

5.5.3 Types of Systems

5.5.3(a) Exhaust gas monitoring systems may be classified under two main headings, namely extractive and in-situ. In extractive monitoring systems the gas is analyzed at a point remote from the source, often after conditioning of the sample has taken place by one, or a combination of processes such as filtering, drying, heating or cooling; this type of system allows for analysis by electrochemical cell, chemiluminescence, paramagnetics or optical radiation. In in-situ monitoring systems the measurement takes place in the stack with no conditioning of the exhaust gas and is only suitable for analysis by optical radiation.

5.5.3(b) The choice of analyser will be dependent upon the gas or gases to be measured, the measuring environment, the system classification (extractive versus in-situ) and the type of monitoring to be carried out (continuous, semi-continuous, intermittent or spot check):

electrochemical cells rely on the change in electrical resistance of a gas sensitive chemical when a particular gas passes over it and are suitable for use with most gases; this methodology is popular with manufacturers of both portable and fixed gas detectors, but is adversely affected by cross sensitivity and moisture, it also has a limited life (maximum two years) due to the gradual poisoning of the cell by the gases to which it is exposed, although cell replacement is generally straightforward;

chetniluminescent analyzers, whilst limited to the measurement of NOx and ammonia (NH3), are presently the most reliable and accurate method of measurement for NOx and are the preferred method for measurement of this gas in a number of

countries; indeed, they are specified in the International Standards Organization (ISO) standard ISO 8178, Part 1 on which the NO Technical Code is based.

Analysis is achieved by measuring the light emitted when nitric oxide (NO) is converted to nitrogen dioxide (NO2) in the presence of ozone (03) whilst ammonia content is calculated after first converting it to nitric oxide in a high temperature oven;

ABS GUIDANCE NOTES ON PREVENTION OF AIR POLLUTION FROM SHIPS, MARCH 1999 47

Section

The uture

iii) paramagnetic analyzers are normally specified for the measurement of oxygen (02 ) which is one of the few gases that exhibits magnetic properties; analysis is accomplished by measuring the movement of a magnetic dumbbell as it is acted upon by the oxygen content of the passing gas. This type of analyser is one of the few that has a proven track record in the marine environment, being the preferred method of measuring the oxygen content of shipboard generated inert gas on oil tankers; and,

analysis by optical radiation which involves the measurement of the amount of light energy that is absorbed by the molecules of a particular gas as a light source is passed through it; each individual gas has a unique signature for a given wavelength of light, the preferred types of light being ultraviolet with a wavelength of between 100 to 400 nanornetres (10 9m) and infrared with a wavelength of 700 nm and above.

5.5.3(0 The choice of system, i.e. extractive or in-situ, will also depend upon a number of factors, not least the type of analyser to be used and the gas(es) to be monitored:

extractive systems have the advantage that the analysis of any number of different gases in a process can be carried out in a safe, often air conditioned, area remote from that process environment; this allows for the use of more sensitive equipment and sample treatment techniques which can reduce problems with cross-sensitivity, moisture and particulate contamination. The main disadvantage is that the distance from point of extraction to point of analysis is limited by virtue of pipework friction losses which, in turn, may lead to a number of remote analyser areas being required within a large plant and, where monitoring forms part of a closed loop control system, possible unacceptable time delays being encountered between the extraction of the sample, its analysis and a corrective signal being received by the process controller; and

in-situ monitoring, which is ideally suited to large plant applications and closed loop control systems, the data being processed at or very near the point of measurement and relayed back to a central control room. The disadvantages are that present technology only allows for a maximum of five individual gases to be analyzed by a single measuring head and, because no sample conditioning takes place, the system is more prone to erroneous results from cross-sensitivity and particulate contamination.

5.5.4 Application to Shipping

5.5.4(a) The only regulations in the new Annex VI where compliance could be demonstrated by exhaust gas monitoring are those concerned with NO„, SO,, and incinerators, in fact, only

the NO, Technical. Code refers to "on board direct measurement and monitoring" as a means

of demonstrating that a diesel engine is in compliance with the NOx emission limits.

However, both the NO, and S0x regulations give, as an alternative, the option of installing an

exhaust gas cleaning system or any other equivalent method which gives a reduction of the pollutant to the limits specified in the relevant regulation.

5.5.4(h) Whereas there may be a limited application for the use of NO, monitoring equipment

initially, because it is intended that the regulation will only be applicable to new engines built on or after 1 January 2000, any ship travelling through a SOx Emission Control Area after

entry into force of the Annex will have to comply with an emission standard of 6g SO,,/kWh.

For ships with the option of burning low sulfur (less than 1.5% mlm) fuels this will not be a problem as compliance with the regulation can be demonstrated by appropriate entries in the ship's official log book stating when and where the ship changed over to using low sulfur fuel


Section The Future

and the bunker tan1 tillages at that time; the alternative is to use an exhaust gas scrubber which is where mon'Aoring may well become a necessity.

5.5.4(c) There are many tankers already fitted with scrubbers as part of the inert gas system, simple pipework modifications, coupled where necessary with an upgraded scrubber plant, may allow a percentage of the flue gas to be diverted through the scrubber and then returned to the funnel; thus diluting the remaining untreated gas to meet the required emissions standard; the amount of gas bypassed would be a function of the SO, content of the flue gas

prior to discharge to the atmosphere and this operation could, in the future, be controlled by a simple closed loop system incorporating an SO, analyser. It is interesting to note that steam

turbine driven tankers, or motor tankers with steam driven cargo pumps, where the inert gas system is supplied from the boiler plant rather than independent inert gas generator, would be the most economical to upgrade. However, for safety reasons a simple interlock system would be required to prevent the inadvertent introduction of oxygen enriched exhaust gases, such as those from diesel engine exhausts, to the inert gas system. It may also be the ease that ships, other than tankers with inert gas plants, opt for a scrubber system similar to that described above rather than carrying out modifications to fuel distribution systems to cater for large quantities of two or more grades of fuel.

5.5.4(d) On a similar vein, where an engine manufacturer opts for NO abatement technology

such as selective catalytic reduction, water injection, exhaust gas recirculation or the use of emulsified fuel, the associated control systems may, in the future, rely on feedback from a NO analyser situated downstream of the abatement process for the purposes of optimisation

of engine performance.

A S' GUIDANCE NOTES ON PREVENTION OF AIR POLLUTION FROM SHIPS, MARCH 1999 49

GUIDANCE NOTES ON


SECTION 6 Conclusions


GUIDANCE NOTES ON


FROM SHIPS

SECTION 6 Conclusions

I Regardless of presently available technologies (or lack of them) for the reduction and prevention of ship generated air pollution the international shipping community has been left in no doubt as to the growing concerns of environmentally conscious countries, and relevant international organizations, with respect to what is now considered to be an unacceptably high percentage contribution to global air pollution from shipping. As international emission reduction strategies result in increasingly stringent discharge limits being applied to land-based industries, so the shipping industry will feel the knock-on effects of such legislation and be subjected to ever greater scrutiny and further tightening of the air pollution controls already adopted by MARPOL Annex VI..

3 As has been the case with other Annexes to MARPOL, the length of time between adoption of Annex VI and its entry into force is likely to be determined by international pressures resulting from public concerns on the effects of air pollution in various parts of the world. It has already been pointed out that, unlike other forms of marine pollution, air pollution is transboundary in nature and can therefore affect land-locked countries as well as those with coastlines. There can be few, if any, environmentally aware people in the civilized world who have not heard of global warming, the ozone layer, acid rain and smog; indeed, hardly a week passes without the publication of further evidence of the effects of man's continuing pollution of the atmosphere that surrounds planet earth. Most people are aware of the hole in the ozone layer and the rapid increase in the incidents of skin cancer which have been attributed to this; acid rain not only kills forests and poisons water courses, it also destroys the fabric of buildings; air quality in many urban areas is now so poor that not only is it measured but the results are broadcast to alert vulnerable members of the public, primarily those with respiratory problems; and of course, who is not familiar with the predictions regarding climatic change that may occur as a result of global warming, the associated rises in sea levels as the polar ice caps melt and the probable flooding of low lying coastal areas throughout the world.

There is nothing that the international shipping community can do to reverse the continuing quest for a cleaner global environment; indeed, to ignore the concerns and requests for co-operation from international organizations, such as the UNFCCC, may result in decisions taken by the IMO's Marine Environmental Protection Committee being effectively over-ruled by other United Nations bodies who have relevant expertise in matters concerning protection of the environment.


Section 6 Conclusions

7

On the positive side, improvements in the design and operation of marine diesel engines have seen a relative drop of some 30% in the levels of CO2 discharged to the atmosphere per ton of cargo moved;

regional agreements and/or requirements in some of the more sensitive parts of the world are already giving local improvements to air quality; and, concerns regarding shipping's contribution to global atmospheric pollution have resulted in concerted attempts to categorize and document the amounts of the various pollutants attributed to international transport.

9

On the negative side, the improvements in CO, emissions from diesel engines noted above have

generally resulted in increased NOx emissions; proposed and pending legislation, such as the

requirements for NO reductions, ballast water exchange (for the minimization of transfer of harmful

aquatic organisms and pathogens) and the banning of anti-fouling paints containing TBTs are all likely to increase CO2 and other exhaust gas emissions due to an increase in a vessel's fuel oil

consumption; and, regional agreements and requirements for pollution reduction strategies can result in trade distortion, the transfer of cargoes to other less environmentally friendly modes of transport and possible increases in air pollution for surrounding areas due to a shift in vessel trading patterns.

11

As can be seen from some of the above examples there are certain types of pollution presently under consideration where the preferred reduction strategy will result in an increase in emissions to the atmosphere of one or more of the pollutants to be controlled by the new Annex VI to MARPOL, The interrelationship between these various different types of pollution, and their means of control, will need to be carefully considered on the basis of a cost benefit analysis to ensure that a balance is struck between benefits to the environment and cost to the industry. It is therefore extremely important that the International shipping community continues to promote the environmentally friendly aspects of the transportation of cargo by sea compared to other modes of transport and, where possible, to demonstrate a commitment to reducing global atmospheric pollution by equipping and operating ships, as far as is reasonably practicable, in accordance with the requirements of the new Annex VI to MARPOL.

13

In order to assist owners and operators of ships, offshore platforms, drilling units and other marine structures, as well as surveyors, builders, designers and manufacturers of marine equipment, in assessing and accessing forthcoming legislation from flag Administrations and environmental agencies, these Guidance Notes contain, at appendix 7, a list of useful web site addresses that were available as of the end of March 1999.


GUIDANCE NOTES ON


APPENDIX 11 Chapter IH of Annex VI on the

Requirements for Control of Emissions From Ships

CONTENTS

REGULATION 12

REGULATION 13

REGULATION 14

REGULATION 15

REGULATION 16

REGULATION 17

REGULATION 18

REGULATION 19

Ozone Depleting Substances 57 Nitrogen Oxides (N0x) 57

Sulphur Oxides (S0x) 59

Volatile Organic Compounds 60

Shipboard Incineration 60

Reception Facilities 61

Fuel Oil Quality 62

Requirements for Platforms and Drilling Rigs 64

A S GUIDANCE NOTES ON PREVENTION OF AIR POLLUTION FROM SHIPS. MARCH 1999 55

(1 )

GUIDANCE NOTES ON


FROM SHIPS

APPENDIX 1 Chapter III of Annex VI on the

Requirements for Control of Emissions From Ships

REGULATION 12 Ozone Depleting Substances

Subject to the provisions of regulation 3, any deliberate emissions of ozone depleting substances shall be prohibited. Deliberate emissions include emissions occurring in the course of maintaining, servicing, repairing or disposing of systems or equipment, except that deliberate emissions do not include minimal releases associated with the recapture or recycling of an ozone depleting substance. Emissions arising from leaks of an ozone depleting substance, whether or not the leaks are deliberate, may be regulated by Parties to the Protocol of 1997.

New installations which contain ozone depleting substances shall be prohibited on all ships, except that new installations containing hydro-chlorofluorocarbons (HCFCs) are permitted until 1 January 2020.

The substances referred to in this regulation, and equipment containing such substances, shall be delivered to appropriate reception facilities when removed from ships.

REGULATION 13 Nitrogen Oxides (NO.)

(1) (a) This regulation shall apply to:

i) each diesel engine with a power output of more than 130 kW which is installed on a ship constructed on or after 1 January 2000; and

each diesel engine with a power output of more than 130 kW which undergoes a major conversion on or after 1 January 2000.

(b) This regulation does not apply to:

i) emergency diesel engines, engines installed in lifeboats and any device or equipment intended to be used solely in case of emergency; and


Appendix 1 Chapter M of MARPOL Annex VI

engines installed on ships solely engaged in voyages within waters subject to the sovereignty or jurisdiction of the State the flag of which the ship is entitled to fly, provided that such engines are subject to an alternative NO

control measure established by the Administration.

(c)

Notwithstanding the provisions of sub-paragraph (a) of this paragraph, the Administration may allow exclusion from the application of this regulation to any diesel engine which is installed on a ship constructed, or on a ship which undergoes a major conversion, before the date of entry into force of the present Protocol, provided that the ship is solely engaged in voyages to ports or offshore terminals within the State the flag of which the ship is entitled to fly.

(2) (a) For the purpose of this regulation, "major conversion" means a modification of an engine where:

the engine is replaced by a new engine built on or after 1 January 2000, or

it) any substantial modification, as defined in the NO Technical Code, is made

to the engine, or

Hi) the maximum continuous rating of the engine is increased by more than 10%.

(b) The NO emission resulting from modifications referred to in the sub-paragraph (a)

of this paragraph shall be documented in accordance with the NO Technical Code

for approval by the Administration.

(3) (a) Subject to the provision of regulation 3 of this Annex, the operation of each diesel engine to which this regulation applies is prohibited, except when the emission of nitrogen oxides (calculated as the total weighted emission of NO,) from the engine is

within the following limits:

i) 17.0g/kWh when n is less than 130 rpm

it) 45.0*n(-°2) g/kWh when n is 130 or more but less than 2000 rpm

iii) 9.8 g/kWh when n is 2000 rpm or more

where n = rated engine speed (crankshaft revolutions per minute).

When using fuel composed of blends from hydrocarbons derived from petroleum refining, test procedure and measurement methods shall be in accordance with the NO Technical Code, taking into consideration the Test Cycles and Weighting

Factors outlined in appendix II to this Annex.

(b) Notwithstanding the provisions of sub-paragraph (a) of this paragraph, the operation of a diesel engine is permitted when:

i) an exhaust gas cleaning system, approved by the Administration in accordance with the NO„ Technical Code, is applied to the engine to reduce

onboard NO emissions at least to the limits specified in sub-paragraph (a),

Or

ii) any other equivalent method, approved by the Administration taking into account relevant guidelines to be developed by the Organization, is applied to reduce onboard NO emissions at least to the limit specified in sub-

paragraph (a) of this paragraph.


Appendix 'I Chapter III of MARPOL Annex VI

REGULATION 14 Sulphur Oxides (SOX}

General requirements

(1) The sulphur content of any fuel oil used on board ships shall not exceed 4.5% m/m.

(2) The worldwide average sulphur content of residual fuel oil supplied for use on board ships shall be monitored taking into account guidelines to be developed by the Organization.

Requirements within SOX Emission Control Areas

(3)

For the purpose of this regulation, SO, Emission Control Areas shall include:

(a) the Baltic Sea area as defined in regulation 10(1)(b) of Annex 1; and

(b) any other sea area, including port areas, designated by the Organization in accordance with criteria and procedures for designation of SO, Emission Control

Areas with respect to the prevention of air pollution from ships contained in appendix 111 to this Annex.

(4) While ships are within SO, Emission Control Areas, at least one of the following conditions

shall be fulfilled:

(a) the sulphur content of fuel oil used on board ships in a SO„ Emission Control Area

does not exceed 1.5% mina;

(b) an exhaust gas cleaning system, approved by the Administration taking into account guidelines to be developed by the Organization, is applied to reduce the total emission of sulphur oxides from ships, including both auxiliary and main propulsion engines, to 6.0 g SO,/kWh or less calculated as the total weight of sulphur dioxide

emission. Waste streams from the use of such equipment shall not be discharged into enclosed ports, harbours and estuaries unless it can be thoroughly documented by the ship that such waste streams have no adverse impact on the ecosystems of such enclosed ports, harbours and estuaries, based upon criteria communicated by the authorities of the port State to the Organization. The Organization shall circulate the criteria to all Parties to the Convention; or

(c) any other technological method that is verifiable and enforceable to limit SO,

emissions to a level equivalent to that described in sub-paragraph (b) is applied. These methods shall be approved by the Administration taking into account guidelines to be developed by the Organization.

(5)

The sulphur content of fuel oil referred to in paragraph (1) and sub-paragraph (4)(a) of this regulation shall be documented by the supplier as required by regulation 18 of this Annex.

(6) Those ships using separate fuel oils to comply with paragraph (4)(a) of this regulation shall allow sufficient time for the fuel oil service system to be fully flushed of all fuels exceeding 1.5% m/m sulphur content prior to entry into a SO, Emission Control. Area. The volume of

low sulphur fuel oils (less than or equal to 1.5% sulphur content) in each tank as well as the date, time, and position of the ship when any fuel-changeover operation is completed, shall be recorded in such log-book as prescribed by the Administration.

(7)

During the first twelve months immediately following entry into force of the present Protocol, or of an amendment to the present Protocol designating a specific SO), Emission

Control Area under paragraph (3)(b) of this regulation, ships entering a SO, Emission

Control Area referred to in sub-paragraph (3)(a) of this regulation or designated under

AS' GUIDANCE NOTES ON PREVENTION OF AIR POLLUTION FROM SHIPS, MARCH 1999 59

Appendix 1 Chapter 01 of MARPOL Annex VI

paragraph (3)(b) of this regulation are exempted frorr: the requirements in paragraphs (4) and (6) of this regulation and from the requirements of paragraph (5) of this regulation insofar as they relate to sub-paragraph (4)(a) of this regulation.

REGULATION 15 Volatile Organic Compounds

( t ) [f the emissions of volatile organic compounds (VOCs) from tankers are to be regulated in ports or terminals under the jurisdiction of a Party to the Protocol of 1997, they shall be regulated in accordance with the provisions of this regulation.

(2) A Party to the Protocol of 1997 which designates ports or terminals under its jurisdiction in which VOCs emissions are to be regulated, shall submit a notification to the Organization. This notification shall include information on the size of tankers to be controlled, on cargoes requiring vapour emission control systems, and the effective date of such control. The notification shall be submitted at least six months before the effective date.

(3) The Government of each Party to the Protocol of 1997 which designates ports or terminals at which VOCs emissions from tankers are to be regulated shall ensure that vapour emission control systems, approved by that Government taking into account the safety standards developed by the Organization, are provided in ports and terminals designated, and are operated safely and in a manner so as to avoid undue delay to the ship.

(4) The Organization shall circulate a list of the ports and terminals designated by the Parties to the Protocol of 1997 to other Parties to the Protocol of 1997 and Member States of the Organization for their information.

(5) All tankers which are subject to vapour emission control in accordance with the provisions of paragraph (2) of this regulation shall be provided with a vapour collection system approved by the Administration taking into account the safety standards developed by the Organization , and shall use such system during the loading of such cargoes. Terminals which have installed vapour emission control systems in accordance with this regulation may accept existing tankers which are not fitted with vapour collection systems for a period of three years after the effective date identified in paragraph (2).

(6) This regulation shall only apply to gas carriers when the type of loading and containment systems allow safe retention of non-methane VOCs on board, or their safe return ashore.

REGULATION 16 Shipboard Incineration

(1) Except as provided in paragraph (5), shipboard incineration shall be allowed only in a shipboard incinerator.

(2) (a)

Except as provided in sub-paragraph (b) of this paragraph, each incinerator installed on board a ship on or after 1 January 2000 shall meet the requirements contained in appendix IV to this Annex. Each incinerator shall be approved by the Administration taking into account the standard specifications for shipboard incinerators developed by the Organization .

(b) The Administration may allow exclusion from the application of sub- paragraph (a) of this paragraph to any incinerator which is installed on board

Refer to MSC/Circ.585, Standards for vapour emission control systems.

Refer to IVISC/Cire.585, Standards for vapour emission control systems.

Refer to resolution MEPC 76(40), Standard specification for shipboard incinerators.

60 ABS' GUIDANCE NOTES ON PREVENTION OF AIR POLLUTION FROM SHIPS. MARCH 1999

Appendix Chapter III of MARPOL Annex VI

a ship before the date of entry into force of the Protocol of 1997, provided that the ship is solely engaged in voyages within waters subject to the sovereignty or jurisdiction of the State the flag of which the ship is entitled to fly.

(3) Nothing in this regulation affects the prohibition in, or other requirements of, the Convention on the Prevention of Marine Pollution by Dumping of Wastes and Other Matter, 1972, as amended, and the 1996 Protocol thereto.

(4) Shipboard incineration of the following substances shall be prohibited:

(a) Annex I, H and III cargo residues of this convention and related contaminated packing materials;

(b) polychlorinated biphenyls (PCBs);

(c) garbage; as defined in Annex V of the present Convention, containing more than traces of heavy metals; and

(d) refined petroleum products containing halogen compounds.

(5) Shipboard incineration of sewage sludge and sludge oil generated during the nonnal operation of a ship may also take place in the main or auxiliary power plant or boilers, but in those cases, shall not take place inside ports, harbours and estuaries.

(6) Shipboard incineration of polyvinyl chlorides (PVCs) shall be prohibited, except in shipboard incinerators for which IMO Type Approval Certificates have been issued.

(7) All ships with incinerators subject to this regulation shall possess a manufacturer's operating manual which shall specify how to operate the incinerator within the limits described in paragraph 2 of appendix IV to this Annex.

(8) Personnel responsible for operation of any incinerator shall be trained and capable of implementing the guidance provided in the manufacturer's operating manual.

(9) Monitoring of combustion flue gas outlet temperature shall be required at all times and waste shall not be fed into a continuous-feed shipboard incinerator when the temperature is below the minimum allowed temperature of 850°C. For batch-loaded shipboard incinerators, the unit shall be designed so that the temperature in the combustion chamber shall reach 600°C within 5 minutes after start-up.

(10) Nothing in this regulation precludes the development, installation and operation of alternative design shipboard thermal waste treatment devices that meet or exceed the requirements of this regulation.

REGULATION 17 Reception Facilities

(1)

The Government of each Party to the Protocol of 1997 undertakes to ensure the provision of facilities adequate to meet the:

(a) needs of ships using its repair ports for the reception of ozone depleting substances and equipment containing such substances when removed from ships;

(b) needs of ships using its ports, terminals or repair ports for the reception of exhaust gas cleaning residues from an approved exhaust gas cleaning system when discharge into the marine environment of these residues is not petinitted under regulation 14 of this Annex;


Appendix 1 Chapter III of MARPOL Annex VI

without causing undue delay to ships, and

(c) needs in ship breaking facilities for the reception of ozone depleting substances and equipment containing such substances when removed from ships.

(2) Each Party to the Protocol of 1997 shall notify the Organization for transmission to the Members of the Organization of all cases where the facilities provided under this regulation are unavailable or alleged to be inadequate.

REGULATION 18 Fuel Oil Quality

(1)

Fuel oil for combustion purposes delivered to and used on board ships to which this Annex applies shall meet the following requirements:

(a) except as provided in sub-paragraph (b):

i) the fuel oil shall be blends of hydrocarbons derived from petroleum refining. This shall not preclude the incorporation of small amounts of additives intended to improve some aspects of performance;

ii) the fuel oil shall be free from inorganic acid;

iii) the fuel oil shall not include any added substance or chemical waste which either:

(I) jeopardizes the safety of ships or adversely affects the performance of the machinery, or

(2) is harmful to personnel, or

(3) contributes overall to additional air pollution; and

(b) fuel oil for combustion purposes derived by methods other than petroleum refining shall not:

i) exceed the sulphur content set forth in regulation 14 of this Annex;

ii) cause an engine to exceed the NO emission limits set forth in regulation

13(3)(a) of this Annex;

iii) contain inorganic acid; and

iv) (1)

jeopardizes the safety of ships or adversely affects the performance of the machinery, or

(2) is harmful to personnel, or

(3) contributes overall to additional air pollution.

(2) This regulation does not apply to coal in its solid form or nuclear fuels.

(3) For each ship subject to regulations 5 and 6 of this Annex, details of fuel oil for combustion purposes delivered to and used on board shall be recorded by means of a bunker delivery note which shall contain at least the infoiniation specified in appendix V to this Annex.

(4) The bunker delivery note shall be kept on board the ship in such a place as to be readily available for inspection at all reasonable times. It shall be retained for a period of three years after the fuel oil has been delivered on board.

(5) (a) The competent authority of the Government of a Party to the Protocol of 1997 may

Refer to resolution A787(19), Procedures for port State control.


Appendix 1 Chapter III of MARPOL. Annex VI

inspect the bunker delivery notes on board any ship to which this Annex applies while the ship is in its port or offshore terminal, may make a copy of each delivery note, and may require the master or person in charge of the ship to certify that each copy is a true copy of such bunker delivery note. The competent authority may also verify the contents of each note through consultations with the port where the note was issued.

(b) The inspection of the bunker delivery notes and the taking of certified copies by the competent authority under this paragraph shall be perfoimed as expeditiously as possible without causing the ship to be unduly delayed.

(6) The bunker delivery note shall be accompanied by a representative sample of the fuel oil delivered having regard to guidelines to be developed by the Organization. The sample is to be sealed and signed by the supplier's representative and the master or officer in charge of the bunker operation on completion of bunkering operations and retained under the ship's control until the fuel oil is substantially consumed, but in any case for a period of not less than twelve months from the time of delivery.

Parties to the Protocol of 1997 undertake to ensure that appropriate authorities designated by them:

(a) maintain a register of local suppliers of fuel oil;

(b) require local suppliers to provide the bunker delivery note and sample as required by this regulation, certified by the fuel oil supplier that the fuel oil meets the requirements of regulations 14 and 18 of this Annex;

(c) require local suppliers to retain a copy of the bunker delivery note for at least 3 years for inspection and verification by the port State as necessary;

(d) take action as appropriate against fuel oil suppliers that have been found to deliver fuel oil that does not comply with that stated on the bunker delivery note;

(e) inform the Administration of any ship receiving fuel oil found to be noncompliant with the requirements of regulations 14 or 18 of this Annex; and

(0 inform the Organization for transmission to Parties to the Protocol of 1997 of all cases where fuel oil suppliers have failed to meet the requirements specified in regulations 14 or 18 of this Annex.

In connection with port State inspections carried out by Parties to the Protocol of 1997, the Parties further undertake to:

(a) inform the Party or non-Party under whose jurisdiction bunker delivery note was issued of cases of delivery of noncompliant fuel oil, giving all relevant information;

(b) ensure that remedial action as appropriate is taken to bring noncompliant fuel oil discovered into compliance.

(7)

(8)


Appendix 1 Chapter ill of MARPOL Annex VI

REGULATION 19 Requirements for Platforms and Drilling Rigs

Subject to the provisions of paragraphs (2) and (3) of this regulation, fixed and floating platforms and drilling rigs shall comply with the requirements of this Annex.

(2) Emissions directly arising from the exploration, exploitation and associated offshore processing of sea-bed mineral resources are, consistent with article 2(3)(b)(ii) of the present Convention, exempt from the provisions of this Annex. Such emissions include the following:

(a) emissions resulting from the incineration of substances that are solely and directly the result of exploration, exploitation and associated offshore processing of sea-bed mineral resources, including but not limited to the flaring of hydrocarbons and the burning of cuttings, muds, and/or stimulation fluids during well completion and testing operations, and flaring arising from upset conditions;

(b) the release of gases and volatile compounds entrained in drilling fluids and cuttings;

(e) emissions associated solely and directly with the treatment, handling, or storage of sea-bed minerals; and

(d) emissions from diesel engines that are solely dedicated to the exploration, exploitation and associated offshore processing of sea-bed mineral resources.

(3)

The requirements of regulation 18 of this Annex shall not apply to the use of hydrocarbons which are produced and subsequently used on site as fuel, when approved by the Administration.


GUIDANCE NOTES ON


APPENDIX 2 Information to be Included in the

Bunker Delivery Note (Regulation 18(3))

Name and IMO number of receiving 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)*

Fuel oil should be tested in accordance with ISO 3675 Fuel oil should be tested in accordance with ISO 8754

ABS ' GUIDANCE NOTES ON PREVENTION OF AIR POLLUTION FROM SHIPS. MARCH 1999 65

GUIDANCE NOTES ON


APPENDIX 3 Notification to the Organization on Ports or Terminals where Volatile

Organic Compounds(VOCs) Emissions are to be Regulated

MEPC/Circ.345 November 1998 Original: ENGLISH

1, The Marine Environment Protection Committee at its forty-second session held from 2 to 6 November 1998, considered the provisions of regulation 15 of Annex VI to MARPOL 73/78. While recognising that MARPOL 73/78 Annex VI is not yet in force, the Committee noted that some Member Governments intend to implement national regulations for control of volatile organic compound emissions requiring Vapour Emission Control Systems.

2. The Committee noted that regulation 15 of Annex VI to MARPOL 73/78 requires Member Governments to inform the Organisation of their intention to introduce the requirements for the use of such systems and notify the Organisation on ports and terminals under their jurisdiction where such requirements are already in force. Notification should be submitted six months prior to the effective date of implementing such systems to allow tankers to timely fit required piping, etc.

3. The Committee further noted that there are several terminals that are already implementing or operating such practices. The Committee shared the concern that, since there is no circulation of such information, it is difficult for owners to prepare for these changes at ports and terminals

4. Member Governments are invited to notify the Organisation with information on ports and terminals under its jurisdiction at which volatile organic compound emissions are to be regulated, and requirements to be imposed on ships calling at these ports and ter urinals.

5. With the aim of promoting full utilisation of vapour recovery systems in ports and terminals, any information received by the Organisation on the availability of vapour recovery systems will be circulated through MEPC circulars so that owners will have up-to-date information on existing or planned vapour recovery systems.

ABS GUIDANCE NOTES ON PREVENTION OF AIR POLLUTION FROM SHIPS. MARCH 1999 67

GUIDANCE NOTES ON


FROM SHIPS

APPENDIX 4 Definitions

For the purpose of MARPOL Annex VI:

A similar stage of construction means the stage at which:

(a) construction identifiable with a specific ship begins; and

(b) assembly of that ship has commenced comprising at least 50 tonnes or one per cent of the estimated mass of all structural material, whichever is less.

Continuous feeding is defined as the process whereby waste is fed into a combustion chamber without human assistance while the incinerator is in normal operating conditions with the combustion chamber operative temperature between 850°C and 1200°C.

Emission means any release of substances, subject to control by Annex VI from ships into the atmosphere or sea

New installations, in relation to regulation 12 of Annex VI, means the installation of systems, equipment. including new portable fire extinguishing units, insulation, or other material on a ship after the date on which the Annex enters into force, but excludes repair or recharge of previously installed systems, equipment, insulation, or other material, or recharge of portable fire extinguishing units.

NO Technical Code means the Technical Code on Control of Emission of Nitrogen Oxides from

Marine Diesel Engines adopted by Conference resolution 2, as may be amended by the Organization, provided that such amendments are adopted and brought into force in accordance with the provisions of article 16 of the present Convention concerning amendment procedures applicable to an appendix to an Annex.

Ozone depleting substances means controlled substances defined in paragraph 4 of article 1 of the Montreal Protocol on Substances that Deplete the Ozone Layer, 1987, listed in Annexes A, B, C or E to the said Protocol in force at the time of application or interpretation of this Annex.

Ozone depleting substances that 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 Baton 114B2)

CFC-11Triehlorofluoromethane

CFC- 12 Dichlorodifluoromethane


Appendix 4 Definitions

CFC- 113 1.1.2-Trichloro-1,2,2-trifluoroethane

CFC-114 1.2-D iehloro-1,1,2,2-tetrafluoroethane

CFC-115 Chloropentafluoroethane

Sludge oil means sludge from the fuel or lubricating oil separators, waste lubricating oil from main or auxiliary machinery, or waste oil from bilge water separators, oil filtering equipment or drip trays.

Shipboard incineration means the incineration of wastes or other matter on board a ship, if such wastes or other matter were generated during the normal operation of that ship.

Shipboard incinerator means a shipboard facility designed for the primary purpose of incineration.

Ships constructed means ships the keels of which are laid or which are at a similar stage of construction.

SO, Emission Control Area means an area where the adoption of special mandatory measures for SO,

emissions from ships is required to prevent, reduce and control air pollution from SO, and its

attendant adverse impacts on land and sea areas. SO, Emission Control Areas shall include those

listed in regulation 14 of Annex VI.

Tanker means an oil tanker as defined in regulation 1(4) of Annex I or a chemical tanker as defined in regulation 1(1) of Annex II of the present MARPOL Convention.

The Protocol of 1997 means the Protocol of 1997 to amend the International Convention for the Prevention of Pollution from Ships, 1973, as amended by the Protocol of 1978 relating thereto.

For the purpose of the NO Technical Code:

Nitrogen Oxide (NO) Emissions means the total emission of nitrogen oxides, calculated as the total

weighted emission of NO, and determined using the relevant test cycles and measurement methods as

specified in the NO, Technical Code.

Substantial modification of a marine diesel engine means:

1. For engines installed on ships constructed on or after 1 January 2000, substantial modification means any modification to an engine that could potentially cause the engine to exceed the emission standards set out in regulation 13 of Annex VI. Routine replacement of engine components by parts specified in the Technical File that do not alter emission characteristics shall not be considered a "substantial modification" regardless of whether one part or many parts are replaced.

2. For engines installed on ships constructed before I January 2000, substantial modification means any modification made to an engine which increases its existing emission characteristics established by the simplified measurement method as described in 6.3 of the NO Technical Code in excess of the allowances set out in 6.3.11 of that Code. These

changes include, but are not limited to, changes in its operations or in its technical parameters (e.g., changing camshafts, fuel injection systems, air systems, combustion chamber configuration, or timing calibration of the engine).

Components are those interchangeable parts which influence the NO emissions performance,

identified by their design/parts number.

Setting means adjustment of an adjustable feature influencing the NO emissions performance of an

engine.


Appendix 4 Definitions

Operating values are engine data, like cylinder peak pressure, exhaust gas temperature, etc., from the engine log which are related to the NO emission performance. These data are load-dependent.

The E1APP Certificate is the Engine International Air Pollution Prevention Certificate which relates to NO„ emissions.

The LAPP Certificate is the International Air Pollution Prevention Certificate.

Administration has the same meaning as Article 2, sub-paragraph (5) of MARPOL 73/78.

On-board NO verification procedures mean a procedure, which may include an equipment requirement to be used on board at initial certification survey or at the periodical and intermediate surveys, as required, to verify compliance with any of the requirements of this Code, as specified by the engine manufacturer and approved by the Administration.

Marine diesel engine means any reciprocating internal combustion engine operation on liquid or dual fuel, to which regulations 5, 6 and 13 of Annex VI apply, including booster/compound systems if applied.

Rated power means the maximum continuous rated power output as specified on the nameplate and in the Technical File of the marine diesel engine to which regulation 13 of Annex VI and the NO Technical Code apply.

Rated speed is the crankshaft revolutions per minute at which the rated power occurs as specified on the nameplate and in the Technical File of the marine diesel engine.

Brake power is the observed power measured at the crankshaft or its equivalent, the engine being equipped only with the standard auxiliaries necessary for its operation on the test bed.

On board conditions means that an engine is:

1. installed on board and coupled with the actual equipment which is driven by the engine; and

2. under operation to perform the purpose of the equipment.

A technical file is a record containing all details of parameters, including components and settings of an engine, which may influence the NO„ emission of the engine, in accordance with 2.4 of the NO„ Technical Code.

A record book of engine parameters is the document for recording all parameter changes, including components and engine settings, which may influence NOR, emission of the engine.


GUIDANCE NOTES ON


FROM SHIPS

APPENDIX 5 Interim Guidelines for the

Application of the NO Technical Code

MEPC/Circ.344 November 1998 Original: ENGLISH

1. The Conference of Parties to the International Convention for the Prevention of Pollution from Ships, 1973, as modified by the Protocol of 1978 relating thereto, held from 15 to 26 September 1997 in conjunction with the Marine Environment Protection Committee's fortieth session, adopted under Conference Resolution 2, the Technical Code on Control of Emission of Nitrogen Oxides from Marine Diesel Engines (The NO Technical Code).

2. The purpose of the NOx Technical Code is to establish mandatory procedures for the testing,

survey and certification of marine diesel engines which will enable engine manufacturers, ship owners and Administrations to ensure that all applicable marine diesel engines comply with the relevant limits for emission values of NO, as specified in regulation 13 of Annex VI

to MARPOL 73/78.

3. It is noted that regulation 13 of MARPOL Annex VI is intended to be effective on or after 1 January 2000. While enforcement of the requirements are not feasible before entry into force of the Protocol of 1997, it should be clearly understood that engines installed on ships constructed on or after 1 January 2000 or engines which undergo a major conversion on or after 1 January 2000 but before entry into force, will have to meet these requirements once the Protocol enters into force.

4. To allow uniform application of the Code, and to assist Administrations in certifying engines in accordance with it, prior to the date of entering into force of Annex VI, the guidelines attached as an annex to this Circular are recommended to be used.

ABS GUIDANCE NOTES ON PREVENTION OF AIR POLLUTION FROM SHIPS. MARCH 1999 73

GUIDANCE NOTES ON


ANNEX Interim Guidelines for the Application of the NO. Technical Code

I. Each engine which will become, retrospectively, subject to the provisions of regulation 13 of Annex VI of MARPOL 73/78 on its entry into force, should be certified in accordance with the requirements of the NO Technical Code.

2. Pending entry into force of Annex VI and upon satisfactory compliance with the Code, a "Statement of Compliance" with the NOx Technical Code should be issued by the Flag State

Administration, or organization acting on behalf of that Administration. Such "Statement of Compliance" should contain as a minimum the infoi illation as required by appendix 1 of the NO Technical Code.

3. The "Statement of Compliance" is intended as an interim measure pending issuance of the EIAPP and/or IAPP Certificate upon entry into force of Annex VI.

4. Administrations are urged to take into consideration this "Statement of Compliance" when issuing certificates in accordance with Annex VI, whether or not the "Statement of Compliance" was issued by their Administration, or organization acting on behalf of their Administration.

AS, GUIDANCE NOTES ON PREVENTION OF AIR POLLUTION FROM SHIPS, MARCH 1999

75

GUIDANCE NOTES ON


FROM SHIPS

APPENDIX 6 Check Sheet for an Engine

Parameter Check Method

(Refer to 6.2.3.5 of the NO Technical Code)

For some of the parameters listed below, more than one possibility exists for demonstrating compliance. In such cases any one of, or an combination of, the listed methods may be sufficient to show compliance. Approved by the Administration, the ship operator, supported by the engine manufacturer, may choose which method is applicable.

Parameter Description Complies with Technical File

Injection Timing (see Note I)

1111•11111111111111•111111111111•1111111111111111111111111111111111111111111111111111111111111123111 NO N/A 1. Fuelam position or position of a link between the cam and the pump drive (see

Note 2). • ViT index and cam position or position of the barrel (for sleeve

metered pumps). • Other sleeve meter in • device .lease s ec ).

.111

Stan of delivery for certain fuel rack positions. (d arruc .ressure measurement)

ME

11111111111

1111

Mt=

Opening of injection valve for certain load points. e.t. usin_ a Hall sensor or acceleration I ic k u.)

• Load-dependent operating values (see note 3): Charge air pressure

• Combustion peak pressure • Charge air temperature • Exhaust •as temperature

Mil

In ection nozzle So ecification and comtonent identification number. Injection pump Component identification number.

(includin• s ecification for .er and barrel desi Fuel cam I I• i ( ' - =HMI=

11111 2. Start and end of delivery for a specified fuel rack position. (dynamic pressure

measurement) In ection ressure Load-dependent •ressure in the rail (see Note 4 . 11111111111111

Combustion Chamber

Component identification numbers for: Cylinder Head

Piston head IMIIIIIMIll

IIIIII Compression ratio 1. Check for actual clearance

Mil 2. Check for shims in piston road or connection rod

ABS4 GUIDANCE NOTES ON PREVENTION OF AIR POLLUTION FROM SHIPS, MARCH 1999

77

Appendix 6 NO Verification Parameter Check List

Parameter Description Complies Technical

with File

YES NO N/A Turbocharger

(type and build) 1. Model and specification (identification numbers)

2. Load-dependent charge air pressure (see Note 5) Charge air cooler,

Charge air pre-heater

i. Model and specification

2. Load-dependent charge air temperature corrected to reference conditions (see Note 5)

Valve timing (see Note 6)

1. Cam position

2. Check actual timing Water injection

(see Note 7) 1. Load dependent water consumption

Exhaust gas Recirculation (see Note 7)

I . Load-dependent mass flow of recirculated exhaust gas.

2. CO, concentration in the mixture of fresh air and recirculated exhaust gas (i.e.

in the "scavenge air"). 3. 02 concentration in the -scavenge air"

Emulsified fuel 1. Load-dependent fuel rack position.

2. Load-dependent water consumption.

Selective catalytic reduction (SCR)

(see Notes 7 & 8)

Load dependent mass flow of reducing agent and additional periodical spot checks on NOx concentration after SCR.

Note 1:

Note 2:

Note 3:

To assess the actual timing, it is necessary to know the allowable limits for meeting the emission limits or even graphs showing the influence of timing an NOx, based on the test bed NO,

measurement results.

Position of individual cam, or camshaft if cams are not adjustable

Actual values should be compared with a graph showing the correlation of NO versus the

individual variable. Additionally, the compression ratio is to be eolith nied as corresponding to the initial certification value.

Note 4: Common rail systems only - actual pressures should be compared with a graph showing the correlation of NO versus injection pressure.

Note 5: Actual values should be compared with a graph showing the correlation of NOx versus the

individual variable.

Note 6: Only applicable for 4 stroke engines with inlet valve closure before BDC.

Note 7: For assessment, values (monitored/recorded) should be compared against a graph showing the variables influence on NOR.

Note 8: For engines with selective catalytic reduction (SCR) without feedback control, optional NOx

measurement (periodical spot checks or monitoring) is useful to show that the SCR efficiency still corresponds to the state at the time of certification regardless of whether the ambient conditions or the fuel quality led to different raw emissions.

78 ABS'" GUIDANCE NOTES ON PREVENTION OF AIR POLLUTION FROM SHIPS, MARCH 1999

GUIDANCE NOTES ON


APPENDIX 7 Useful Web Site Addresses

This Appendix contains the web site addresses of a number of internationally recognised Institutions as well as those of Marine Administrations and their respective Environmental and other Agencies which were available at the time of going to press. The lack of an entry for a particular Institution, country or State does not necessarily mean that a web site address does not exist, merely that it was not known or available at that time. Details of Administration web sites not included, or corrections/updates to those that are, should be submitted to ABS Corporate Office, Regulatory Affairs Department at:

American Bureau of Shipping

Two World Trade Center: 106th Floor

New York, New York 10048, USA

Tel: +1 212 839 5000

Fax: + 1 212 839 5214

ABS:

ASME:

British Standards Institution (BSI):

Global Engineering Documents (USA):

Institute of Marine Engineers (UK):

International Maritime Organization:

National Board of Boiler & Pressure Vessel Inspectors:

Royal Institute of Naval Architects (RINA):

Year 2000 (Y2K) Problem:

www.eagle.org

www.asme.org

www.bsi.org.uk

www.gtobal.ihs.com

www.imare.org.uk

www.imo.org

www.nationalboard.org

www.rina.org.uk

www.year2000.com


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INTERNET WEB SITE - FLAG ADMIN & ENVIRONMENT AGENCIES

COUNTRY FLAG ADMIN ENVIRONMENTAL AGENCIES OTHER AGENCIES

AUSTRALIA www.amsa.gov.au www.amsa.gov.au/ams&env.turn

BARBADOS www.barbados-ships.demon.co,uk

BELGIUM- www.vici.fgov.be

CANADA www.ccg-gcc.gc.ca TRANSPORT CANADA www.tc.ge.ca

CANADIAN SHIPOWNERS ASSOCIATION www.shipowners.ca

CHILE www.directernar.c1

CROATIA www.vlada.hr

CYPRUS wvvw.shipping.gov.cv ww-w.arinet.com.cy

DENMARK www.sofartsstyrelsen.dk www.mst.dk

ESTONIA www.tsm.ee www.envineekh

EUROPE EUROPEAN COMMISSION:

curopa.eu.int/index-en.htm

EC DIRECTORATES - GENERAL & SERVICES: europa.eu,intienicommidgserv,html

FINLAND www.fma.fi www.vyb.fi

FRANCE www.askfr/plcdouxlcollocs/gouverneanents.htm

GERMANY www.bmvbw.de www,see-bg.de BIJNDESAMT FUR SEESCHIFFAHRT & HYDROGRAPHIE: www.bsh.de

GREECE www.ven.gr www.minenv.gr

HONG KONG www,info.gov.likimardep REGULATIONS: wwwinfo.govilk/mardep/shipord

ISRAEL Mot [email protected]

www.transportinavigazioneit

Marinenvi&netvision.net.il „,

www.associvile@

PORT AUTHORITIES

www.transportinavigazionc.itiprimapaginaltm ITALIA NOSTRA

www.ssnet.it/italianostrafinth/info,htm

ITALY

KOREA www.mornaf.go.kr www.moen.v.go.kr

LATVIA www.juras-paravalde((t),vde.tv

LITHUANIA www.gamta.itidefault e,ht-m

KOREA w-ww.momaf. o.kr www.moenv. o. kr

LATVIA www.ruras- aravalde rf2vdc.lv

ua

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INTERNET WEB SITE - FLAG ADMIN & ENVIRONMENT AGENCIES

COUNTRY FLAG ADMIN ENVIRONMENTAL AGENCIES OTHER AGENCIES

LITHUANIA www.gamta.itidefault e. ht

MALAYSIA www.marine.gov.my wwwjas.saims.my DEPT OF TRANSPORT : www.jpj.gov.my/mat.htm

NATIONAL TELECOM COMMISSION : e-mail :[email protected]

SAFETY Sr SPECIAL SERVICES GROUP e-mail: findgbayantel.com.ph COMMISSIONERS OFFICE : e-mail: [email protected]

PHILIPPINES www.marina.gov.ph www.denr.gov.ph

SPAIN www.mma.es

SRI LANKA e-rnail:Dmsmos(a),sltnet. k

SWEDEN www.sjofartsverketse www.environ.se

TAIWAN www.hello.com.twf--classcr

e-maihertp@tpts I .seed.net.tw

TURKEY DOGAL HAYATI KORUMA:

www.com.dhkd.org TEMA: www.vol.com.tr/tema

GEKUL: gekuluakfi.org.tr

UK www.meagency.org.ok/mca/mcahome.

htm

www.environment.detr.gov.uk TIER MAJESTY'S STATIONERY OFFICE (HMSO)

www.hmso.gov.uk

UKRAINE [email protected]

US FEDERAL GOVERNMENT AGENCIES DIRECTORY

www.lib.is-u.edu/govifedgov.html US NAVY SHIPBOARD ENVIRONMENTAL

INFORMATION CLEARINGHOUSE www.navyseie.corn

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

www.epa.gov NATIONAL OCEANIC AND ATMOSPHERIC

.ADMIN www.noaa.gov

NATIONAL INSTITUTE OF STANDARDS AND TECHNOLOGY

www.nist.gov

NAVSEA www.naysea.navy.mil MSC www.msc.navy.mil

USCG (REGULATIONS): www.aecess.gpo.gov/nara/cir

USA USCG www.useg.rnil MARAD marad.clot.gov

DOT www.doLgov

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