MARPOL 73/78 Annex VI Regulations forthe Prevention of Air Pollution from Ships
Ratification Process• Protocol Requirements for entry into force – The Protocol is Ratified by 15 signature States to MARPOL with a combined tonnage of 50% of World tonnage – The Current Status of Ratification is by 22 Countries (Signatories of MARPOL Convention)• The Protocol was fully ratified in accordance with requirements on 18th May 2004 and has ENTERED INTO FORCE on 19th MAY 2005
Flag States Party to the Protocol• Azerbaijan, Bahamas, Bangladesh, Barbados, Bulgaria, Cyprus, Denmark, Finland, Germany, Greece, Japan, Liberia, Marshall Islands, Norway, Panama, St Kitts and Nevis, Samoa, Singapore, Spain, Sweden, United Kingdom, Vanuatu.
Non-Parties to the Protocol What happens then?• All Ships are to comply irrespective of Flag State – Article 5, para 4 of MARPOL Convention – “no more favourable treatment”• No PSC inspections unless Port State laws apply and allow e.g. EU Directive.• Bunker Delivery documentation and sample – here is the difficulty – FSI 13 and MEPC 53.
Why MARPOL Annex VI?• Emission Gases from Ships – Oxides of Nitrogen (NOx) – create Ozone – Sulphur Oxides (SOx) – create acidification – Carbon Dioxide (CO2) – is a GHG – Carbon Monoxide (CO) – Hydrocarbons (HC) – gas, soot and some particulates• The concentration of the differing exhaust gases is variable according to the engine type, engine settings and fuel type.
Overview of Content• The Regulations in the Protocol• The NOx Technical Code• The Supporting Guidelines
The Regulations• There are 19 Regulations but the following Regulations will impact Vessel operation for ALL VESSELS ABOVE 400 grt – Regulation 12 – Ozone Depleting Substances – Regulation 13 – NOx emissions – Regulation 14 – Sulphur Oxide emissions – Regulation 15 – VOC emissions – Regulation 16 – Shipboard Incinerators – Regulation 18 – Fuel Oil Quality control
Regulation 12 Ozone Depleting Substances• “Deliberate” Emissions of Ozone Depleting Substances (HFCs) are prohibited• New installations can only use HCFCs (hydrochlorofluorocarbons) until 1st Jan 2020.• These substances, when removed from ships, must be delivered to reception facilities
Regulation 13 – NOx• For all Engines (except emergency engines) installed on ships after 1st January 2000 of more than 130 kW must comply to this Regulation.• The NOx emission is limited to 17 g/kW h for engines operating at 130 rpm but reducing to 9.8 g/kW h for 2000 rpm. Between these revs the limit is designated by equation: 45 * n(-0.2) g/kW h• Existing engines can become a “new” engine if substantially modified.
Regulation 13 - NOx• Regulation 13 requirements are fully defined by the NOx Technical Code – recommended technical reading. – Certification of the engine on manufacture and checked on installation for settings – Certificates required for Ships – EIAPP & IAPP – PSC Inspection of the engine by • Parameter Check method (Engine Technical File) • Simplified measurement method
Regulation 14 - SOx• The Worldwide sulphur cap on fuel oil is set at 4.5%.• Sulphur Emission Control areas (SECAs) – Areas – Baltic, North Sea and English Channel – Sulphur Level of fuel – 1.5% or; – Alternatively use an exhaust gas cleaning system – Ship must have cleared all pipe systems and tanks and be using low sulphur fuel on entry – Regulations for the 1st SECA comes into force on 19th May 2006.
Shipboard Procedures for SECAs• Plan in advance for entry and enter commencement date of preparation in Logbook together with bunker type quantities onboard.• Logbook entry when entry requirements met and entry into SECA - remember Lat. & Long., date and time, together with bunker figures for each tank.• Maintain daily record of bunker use and quantification of bunker tanks whilst in SECA.• DO NOT COMMENCE SHIFT TO HIGH SULPHUR FUEL UNTIL EXIT FROM SECA. Log existing conditions for bunkers and Lat. & Long. with date and time.
Regulation 15 - VOCs• Subject to individual terminal regulations tankers may have to be equipped with Vapour return manifold.• Notification of VOC control by a port to the IMO shall be 6 months before enforcement.• Tankers can be can accept tankers upto 3 years after the date of VOC control enforcement by the Terminal.• The standard for the design of VOC return manifold and operation is contained in MSC/Circ.585.
Regulation 16 - Incinerators• Incinerators installed after 1st Jan 2000 to meet regulations and must certified to meet the specifications in MEPC Resolution 76(40) (Appendix IV of Annex VI).• Each incinerator must have a manufacturers operations manual.• Crew responsible for the incinerator operation shall be trained and follow the operations manual.
Regulation 16 – Use of Incinerators• The following substances are prohibited from incineration: – Annex I, II and III cargo residues and related packing material. – PCBs. – Garbage as defined by Annex V containing heavy metals. – Petroleum Products containing halogens.• PVC can only be incinerated in type approved incinerators.• Flue gas temperatures shall be monitored and not less than 850 deg C for continuous feed and reach 600 deg C within 5 minutes for batch feed.
Regulation 18 – Fuel Oil Quality• “Fuel oil shall be blends of hydrocarbons derived from petroleum refining”• “Fuel oil shall be free from inorganic acid”• “Fuel oil shall not include any added substance or chemical waste which either: – Jeopardises the safety of ships or adversely affects the performance of the machinery, or – Is harmful to personnel, or – Contributes overall to additional air pollution”
Regulation 18 – Fuel Oil Quality• Bunker Delivery Note (BDN) – Becomes a Statutory document – Must be kept on board for 3 years for inspection and a copy may be taken for further examination by PSC. – Must contain all data required by Appendix V • Name and IMO number of vessel • Port • Date of Commencement of delivery • Details of fuel oil supplier • Product name, quantity , Density at 15 0C and Sulphur content % m/m • A declaration that fuel supplied meets Regulation 14 and 18 requirements
Regulation 18 – Fuel Oil Quality• Fuel Oil Sampling• A sealed sample meeting the requirements in associated guidelines has to supplied to the ship by the bunker supplier• For each individual BDN a sample has to be taken at the vessel’s bunker receiving manifold. (see procedure in associated guidelines) – ISM Manuals ??• The sample label has to be signed by both the bunker supplier’s representative and the vessel’s Chief Engineer.• The sample size shall be not less than 400 mls• The sample is not to be used for any commercial purpose• The sample is to be retained on board for at least 1 year for inspection by PSC as required
Shipboard Procedures for BDN and Samples• Adequate bunker manifold location for sampler attachment• External safe storage location for samples for 1 year period• Log book for sample retention and custody transfer• Safe storage for BDNs and other documents relating to bunkering onboard
Port/Flag State Control Guidelines• Proposed Guidelines from FSI 13 for MEPC 53 approval.• Initial inspections and Primary survey parameters – then “Clear Grounds” for in- depth inspections• “In depth” inspection parameters• Detainable deficiencies• Non-Party ship inspections
Other Gas Emission Requirements• Greenhouse Gas Emissions – Greenhouse Gas Emission Indexing of Ships• CO2 Equation used for “Voyage” Calculations C. Con. Factor * FCi / (M Cargoi * Dist i )Where:C. Con Factor for HFO = 3.11C. Con Factor for MDO = 3.17Distance = Loaded + Ballast distance (nm)
Other Regional Regulations• United States of America – NOx Regulations applicable only to US flagged ships – California Air Resources Board (CARB)• European Union – Directive 1999/32 – Current Directive in force from July 2000 – Subject to extension and amendments and due to come into force 2005
The Future – Crystal Ball time!!• Due to the introduction of new engine technology – e.g. HAM – pressure for further reduction in NOx emissions• International and Regional pressure for further reduction in SOx emissions• Introduction of “Particulate” emission control• Further considerations for VOC control
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