MARPOL Annex VI and Emissions Control

MARPOL ANNEX VI
AND
EMISSIONS CONTROL
Mohd. Hanif Dewan, Chief Engineer and
Maritime Lecturer & Trainer, Bangladesh

MARPOL 73/78
Annex VI
Regulations for the Prevention
of Air Pollution from Ships
2
9/2/2014 Maritime Lecturer & Trainer, Bangladesh

Ratification Process
y 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)
yy The Protocol was fully ratified in accordance with
requirements on 18th May 2004 and has ENTERED
INTO FORCE on 19th MAY 2005
3

Why MARPOL Annex VI?
y Emission Gases from Ships
◦ Oxides of Nitrogen (Nox)
◦ Sulphur Oxides of Sulphur (SOx)
◦ Carbon Dioxide (CO2)
◦ Carbon Monoxide (CO)
◦ Hydrocarbons (HC) – gas, soot and some
particulates
y The concentration of the differing exhaust
gases is variable according to the engine type,
engine settings and fuel type.
4

AIR POLLUTION PREVENTION
1. IMO and Regional Ship Air Emission Developments (cont.)
•• Baltic Sea –– SECA from May 2006
•• North Sea/English Channel–– SECA from Nov 2007
- Major Revision of MARPOL Annex VI completed in Oct 2008
- Revised Annex VI effective from 1 July 2010
•• European Sulphur Directive governing emissions in port
(0.1% S at berth 1 Jan 2010)
•• Port regulations in California (USA), Vancouver (Canada)
for ship berthing The California Air Resources Board (CARB)
adopted the Regulations to reduce emissions from auxiliary diesel engines
and diesel - electric engines operated on ocean-going vessels within
California waters and 24 nautical miles off the California baseline.
•• ISO ongoing work on Marine Fuel Oil specifications
•• Discussion and development : of on-shore power supply - also
called Alternative Marine Power (AMP) or Cold-ironing
•• Green House Gases (GHG) limitations
6

Annex VI - Application Summary
Application:
• All ships of ≥ 400 gross tonnage
• Fixed or floating platforms (drilling rigs)
• Floating craft and submersibles
• Ships constructed before 19 May 2005
• Comply no later than 1st drydock but no later than 3 years after
entry into force
Does not apply:
• When suffering damage to ship or equipment
• When saving life at sea
• When securing safety of ship
Certification:
International Air Pollution Prevention (IAPP) Certificate
Other Certification:
Engine International Air Pollution Prevention (EIAPP) Certificates.
Annex VI requires diesel engines to carry individual certificates,
EIAPP, with regard to NOx emissions.
9/2/2014 Maritime Lecturer & Trainer, Bangladesh 7

Survey:
Subject to Initial, Annual, Intermediate, and Renewal surveys
Annex VI requires that every ship of 400 gross tonnage or above
and every fixed and floating drilling rig and other platforms shall be
subject to the following surveys:
- An initial survey before the ship is put into service or before the
IAPP Certificate is issued for the first time.
- Periodical surveys at intervals specified by the Administration,
but not exceeding five years.
- A minimum of one intermediate survey during the period of
validity of the certificate.
- Renewal survey to revalidate the certificate.
In the case of ships of less than 400 gross tons, the Administration
may establish appropriate measures in order to ensure that Annex
VI is complied with.
Mohd. Hanif Dewan, Chief Engineer and Maritime Lecturer & Trainer, Bang9la/2d/e2s0h14 8

MARPOL Annex VI – Regulations
Ozone depleting substances (ODS) Reg.12
Nitrogen oxides (NOx) Reg.13
Sulphur oxides and Particulate Matter (SOx) Reg.14
Volatile organic compounds (VOC) Reg.15
Shipboard incineration Reg.16
Reception Facilities Reg.17
9

MARPOL Annex VI and the Technical Code have retroactive
requirements for the following:
Regulation 12 ––
Emissions from Ozone depleting substances from
refrigerating plants and fire fighting equipment
- On all ships constructed on or after 19.05.2005.
- Installations which contain ozone-depleting substances,
other than hydrochlorofluorocarbons (HCFC), are prohibited
such as CFC.
- Installations containing hydrochlorflourocarbons (HCFCs)
are prohibited on ships constructed on or after 1.01.2020.
- Emissions from Ozone depleting substances from fighting
equipment such as Halon is also prohibited.
10

ODS –– Regulation 12
• Does not apply to sealed units (Reg.12.1)
•••• Deliberate emissions prohibited (Reg.12.2)
•• Other than Hydrochloroflurocarbon (HCFC) all other ODS
banned in new ships from 19 May 2005 (Reg.12.3.1)
•• HCFC banned in new ships from 1 Jan 2020 (Reg.12.3.2)
•• Delivery to reception facilities following removal (Reg.12.4)
•• Supplement to IAPP lists equipment containing ODS (Reg.12.5)
•• Required to complete an ODS record book approved by
Administration (Reg. 12.6)
–– Recharge, repair or maintenance of equipment
– Discharge (deliberate or not), delivery to reception facilities,
supply

Effects of ODS Regulation 12
• Phase out of CFC and HCFC refrigerants
•• Non availability of supplies of older gases
•••• Move to alternative refrigerant types
– natural substances –– carbon dioxide, ammonia,
propane and cyclo-pentane
– possible safety considerations, toxicity, flammability
•• Alternative technologies – Peltier effect

Refrigerants - Family Tree
Environmentally
Inert
Natural Substances
CFC
Chlorofluorocarbon
Production Ban 1996
HCFC
Hydrochlorofluorocarbon
Transitional Substance
Banned in new plant
HFC
Hydrofluorocarbon
Ozone Friendly
Under question
Environmentally
Inert
Natural Substances
Article 5 countries 2010
1. R11
ODP = 1.0
GWP = 4000
2. R12
ODP = 0 9
1. R22
ODP = 0.055
GWP = 1700
2. R141b (Foam blow)
ODP = 0 11
1. R410A
ODP = 0
GWP = 1890 (High
Pressure)
2 R404A
1. Ammonia
ODP = 0
GWP = <1
2. Carbon Dioxide ODP
0.9 = 0
GWP = 8500
3. R115
(R502) ODP = 0.283
GWP = 5591
0.11
GWP = 630
2. ODP = 0
GWP = 3748 (High
GWP)
3. R507
ODP = 0
GWP = 1.0
3. Propane/ Isobutane
ODP = 0
GWP = 3.0
GWP = 3800 (High
GWP)
4. R407C
ODP = 0
GWP = 1610
ODP – Ozone Depleting Potential
GWP Gl b l W i P t ti l
Maritime Lecturer & Trainer, Bangladesh 13
– Global Warming Potential
9/2/2014

For the ships under regulation 12 of Marpol Annex VI, a list
of equipment containing ozone depleting substances shall
be maintain and in case a ship will have rechargeable
systems containing ozone depleting substances, an Ozone
depleting Substances Record Book shall be maintained on
board.
Entries should be as follows:
- Recharge (full or partial) of equipment containing ODS
- Repair or maintenance on equipments containing ODS
- Discharge of ODS deliberate or non deliberate
- Discharge of ODS to land based reception facilities
- Supply of ODS to ships
14

Regulation 13
Nitrogen Oxide (NOx) emissions from diesel engines:
I. NOx Technical Code
II. Prevention of Nitrogen Oxides emissions
15

Regulation 13 – Application
Applies to:
Diesel engines with a power output more than 130 Kw:
1. installed on a ship constructed on or after 1st January 2000
2. which undergo a major conversion on or after 1st January
2000
Not applicable to:
• Emergency diesel engines
• Engines installed in lifeboats
• Any device or equipment intended to be used solely in case
of emergency

NOx emission limits
Tier I * - Ships constructed 1 Jan 2000 to 31 Dec 2010
Tier II - Ships constructed 1 Jan 2011 to 31 Dec 2015
Tier III ** - Ships constructed 1 Jan 2016 onwards
*NOx limit in original Annex VI ** Within ECA
Tier n < 130 rpm 130 ≤ n < 2000 rpm n ≥ 2000 rpm
I 17.0 g/kWh 45.0*n(-0.2) g/kWh 9.8 g/kWh
II 14.4 g/kWh 44.0*n(-0.2) g/kWh 7.7 g/kWh
III 3.4. g/kWh 9.0*n(-0.2) g/kWh 2.0 g/kWh
n = rated engine speed – crankshaft rpm

NOx emission limits – Approved Method
Ships constructed - 1 Jan 1990 to 31 Dec 1999
Required to fit an “approved method” to enable the engine to
meet Tier I limits.
IMO to be notified of approved method
The approved method to be installed at first renewal survey
12 months after IMO notified the “method” is approved
Tier n < 130 rpm 130 ≤ n < 2000 rpm n ≥ 2000 rpm
I 17.0 g/kWh 45.0*n(-0.2) g/kWh 9.8 g/kWh

‰The NOx-influencing components and settings depend on the
design of the particular engine, and shall be listed in the engine’s
Technical File.
The below list shows typical NOx-influencing parameters, but are
not limited to:
1. Injection timing
2. Injection system components (nozzle, injector, fuel pump)
3. Software no, checksums, or other identification of software
version
4. Hardware for fuel injection control
5. Camshaft components (fuel cam, inlet- and exhaust cam)
6. Valve timing
7. Combustion chamber (piston, cylinder head, cylinder liner)
8. Compression ratio (connecting rod, piston rod, shim, gaskets)
19

9. Turbocharger type and build (internal components)
10. Charge air cooler/charge air pre-heater
11. Auxiliary blower
12. NOx reducing equipment “water injection”
13. NOx reducing equipment “emulsified fuel” (fuel/water
emulsion)
14. NOx reducing equipment “exhaust gas recirculation”
15. NOx reducing equipment “selective catalytic reduction”
The actual Technical File of an engine may include less
components and/or parameters other than the list above,
depending on the particular engine and the specific engine
design.
20

¾3.1.1. New measures on engines of ships built: Jan 1990 –– Dec 1999
The NOx emissions at Tier I level upgraded for engines of power
output > 5,000 kW and per cylinder displacement at or > 90 litres
The upgrading is provided with approved and cost effective method for
NOx limitation and should not:
- reduce the engine rating by more than 1%
- increase the fuel consumption by more than 2%, and
- have negative effect on the engine durability or reliability
For Engines NOT complying with Tier I NOx emission limitations:
•• measures against ship only if there is a certified, efficient commercially
available system
•• rules for certification, verification and documentation of scrubbers
and upgrade at the ship’’s first Renewal Survey if there is an approved
method for upgrading at least to Tier I standard
••• if system not available, the next Annual Survey after that method is
available
21

NOx Reduction Options
For existing engines:
• Use of NOx injectors
• Retarding injection timing
• Temperature control of the charge air
• Exhaust Gas Recirculation (EGR)
• Fuel / water emulsion
• Water injection
• Humid Air Motor (HAM) Technique- addition of wet steam
to the engine
• Selective Catalytic Reduction (SCR)
For new engines:
Engine certification
- Pre-certification,
- Technical file clarification on engine family and group,
- Final certification
22

Engine NOx emission engine certification
• Test bed exhaust emission measurement
• NOx Technical File
- information on components, settings, operating values &
adjustments to maintain NOx emissions within allowable limits
• Issue of Engine International Air Pollution Prevention
(EIAPP) certificate or statement of compliance
- applicable to all engines over 130Kw where Regulation 13 applies
- valid for the engine’s life
• Onboard verification (components or measurement)
initially
23

Onboard NOx Verification Methods:
• Engine Parameter check method
check engine components, settings and operating values against
NOx Technical File
• Simplified Measurement method
confirmation test of NOx emissions to be within the limits of
respective emissions measured on the test bed
• Direct Measurement and Monitoring method
direct measurement of the exhaust flow by flow nozzle or
equivalent metering system; difficulties in terms of direct gaseous
flow measurement; potential errors

Alternative methods of compliance:
• Exhaust gas cleaning systems (same issues for SOx)
– Systems being tested but currently no approved exhaust
gas cleaning method on market
• Other equivalent method approved by the administration
for NOx emission reduction e.g. recirculation
• IMO informed of first “approved method” by Denmark on
5 October 2010

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26

MARPOL Annex VI: Regulation 14
Sulphur Oxides (SOx) and
Particulate Matter (PM)
(SOx a cause of acid rain, sea and soil acidification
Particulate Matter – harmful to human health)

Regulation 14 - Sulphur Oxide (SOx) emissions
- 19 May 2005 Annex VI to MARPOL entered into force.
- The revised Annex VI to MARPOL was adopted by IMO on 10
October 2008.
The sulphur oxide (SOx) and Particulate Matter emissions from
ships will in general be controlled by setting a limit on the
sulphur content of marine fuel oils as follows. The sulphur
content of any fuel oil used on board ships shall not exceed the
following limits:
28

Outside an ECA established
to particulate
Inside an ECA established to
limit SOx and particulate
limit SOx and i i
matter emissions matter emissions
4.50% m/m prior to 1
1.50% m/m prior to 1 July
January 2012
2010
3.50% m/m on and after 1
January 2012
July 2010
January 2020*
January 2015
* depending on the outcome of a review, to be concluded in 2018,
as to the availability of the required fuel oil, this date could be
deferred 2025
to 1 January 2025.
Exhaust gas cleaners/Emission Abatement Technologies
Permitted World wide and in ECA under Reg.4 – Equivalents
(Equivalence option limited to Parties)
29

Sulphur Emission Control Areas (SECA) and Emission
Control Areas (ECA):
1. Baltic Sea - 19 May 2006 (SOx)
2. North Sea and English Channel - 21 November 2007 (Sox)
3. North American area (entered into effect 1 August 2012) – as defined
in Appendix VII of Annex VI of MARPOL (SOx, NOx and PM); and
4. United States Caribbean Sea area (expected to enter into effect 1
January 2014) – as defined in Appendix VII of Annex VI of MARPOL
(SOx, NOx and PM).
30

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31

Emission Control Areas – SOx & NOx
• North American – enters into force on 1August 2011
P t Ri & US Vi i I l d ( d ti t • Puerto Rico Virgin Islands adoption at MEPC 6?)

Most ships which operate both outside and inside these ECA will
therefore operate on different fuel oils in order to comply with the
respective limits. In such cases, prior to entry into the ECA, it is
required to have fully changed-over to using the ECA compliant fuel
oil, regulation 14.6, and to have onboard implemented written
procedures as to how this is to be undertaken. Similarly change-over
from using the ECA compliant fuel oil is not to commence until
after exiting the ECA. At each change-over it is required that the
quantities of the ECA compliant fuel oils onboard are recorded,
together with the date, time and position of the ship when either
completing the change-over prior to entry or commencing change-over
after exit from such areas. These records are to be made in a
logbook as prescribed by the ship’s flag State, in the absence of
any specific requirement in this regard the record could be made,
for example, in the ship’s Annex I Oil Record Book.
33

SOx CONTROL:
- Arrangements for LSFO & HSFO: 2 0r more different
types of fuels.
- Availability ––Bunking strategies
- Switch-over(12 to 24 hrs) will need to be changed
over the fuel for the SECA passages.
- Handling of cylinder oils ––2 qualities may be required.
- More strict follow up through sample requirements,
and control of documentation and procedure to log
down.
34

35

Other Methods for Controlling of Nox and Sox:
- Exhaust gas cleaning system or other equivalent system: May be
used (abatement technologies). The emission criteria for such systems
are 6 g SOx/kWh.
- Relifiquation plants for LNG/LPG carriers: Reduction of NOx, Sox
& cost saving through boiled off gas reuse.
- Alfa Lubricator system: Reduction in cylinder oil consumption.
Reduction in particulate emission.
- Electronic control engine : Programmed fuel injection and exhaust
valve. Reduce fuel & reduction of emission.
- Turbo generator plant: Use of high efficiency air flow for power
take off. Reduce fuel & reduction of emission.
- System integration: Humid air Motor (HAM)- engine intake air
operating with water & exhaust gas recirculation (EGR). 50%
reduction of emission.
- HFO sulfur content – Use of low sulfur oil and modify the
equipments to burn LSFO.
- Dual fuel option for low sulphur restricted areas: Need for
additional tanks and dual fuel engines.
36

37

Regulation 15 -Volatile Organic compounds
emissions from cargo oil tanks of oil tankers
y Oil cargoes give off VOCs
y Controls on volatile emissions from tanker cargo
tanks during loading/ unloading of oil cargoes
y Vapour Emissions Control System (VECS) to be
compliant with MSC/Circ. 585 on Standards for VECS
systems
y Crude oil tankers to have an approved VOC manual
(does not apply to gas carriers - Reg. 15.7 )
38

VOCs - Regulation 15
• For Parties applying Regulation 15 in port(s) and terminal(s):
– Shall submit notification to IMO 6 months before effective date (Reg.15.2)
– Shall take into account IMO safety standards for Vapour Emission Control
Systems
(VECS) (MSC/Circ.585) (Reg.15.5)
• IMO shall circulate list of ports and terminals (Reg.15.4)
• Tankers need to install a VECS approved by Administration (Reg.15.5)
•• Ports/terminals with approved VECS can accept tankers without VECS
for up to 3 years after effective date (Reg.15.5)
• Tankers need to develop and implement a VOC management plan
approved by the Administration (Reg.15.6)
– Procedures for minimizing VOC emissions during loading, sea passage &
discharge, responsible person identified, language, additional VOC during
washing
• Regulation applies to gas carriers for retention of non-methane VOCs
(Reg.15.7) but gas carriers not required to develop and implement a VOC
management plan

Regulation 16 - Emissions from shipboard incinerators
y Incinerators to comply with MEPC.76 (40) & Appendix IV for ships
constructed/incinerator installed after 1 January 2000 (Reg. 16.6.1)
y Prohibits incineration of (Reg.16.2):
- MARPOL Annex I, II & III cargoes, Polychlorinated biphenyls (PCB),
garbage containing heavy metals, refined petroleum products containing
halogens, sewage and sludge oil not generated on board, exhaust gas
cleaning system residues
y Permits incineration of:
- PVC – plastics (where type approved to do so) (Reg.16.3)
- Sewage sludge and sludge oil permitted in boilers but not when in
ports, harbours and estuaries (Reg.16.)
y Incinerators installed before 24 May 2005 on domestic shipping can be
excluded by the Administration (Reg. 16.6.2)
y Operating manual, training, and temperature control (Reg. 16.7 –16.9)
Maritime Lecturer & Trainer, Bangladesh
9/2/2014 40

Reception Facilities – Regulation 17
• Parties obliged to provide facilities without causing delay for:
– Reception of ODS in ship repair yards
(Reg.17.1.1)
– Reception of Exhaust Gas Cleaning System residues (Reg.17.1.2)
• Reception of ODS in ship breaking facilities
(Reg.17.1.3)
• If unable to provide reception facilities then Party shall inform IMO
(Reg.17.2 & 17.3)

Regulation 18 - Fuel Oil quality.
y Parties to promote availability of compliant fuel oils and
inform IMO (Reg.18.1)
y Ship found not to be in compliance (Reg.18.2.1)
– Record of actions taken to achieve compliance
– Need to demonstrate “best efforts” to obtain compliant
fuel
y Ship should not be required to deviate or delay unduly the
voyage in order to achieve compliance (Reg.18.2.2)
y Party required to take into account all relevant
circumstances to determine action (Reg.18.2.3)
y Ship required to notify Administration and port of
destination when unable to purchase compliant fuel
(Reg.18.2.4)
y Party to notify when ship presents evidence of non-availability
(Reg.18.2.5)
42

• Required properties of fuel oil identified (Reg.18.3)
• Excludes coal, nuclear and gas fuels from some of the provisions (Reg.
18.4)
• When receiving fuel oil ships of 400 gross tonnage and above are required
to receive a bunker delivery note (BDN) containing information in Appendix
V (Reg. 18.5)
• BDN required to be retained for 3 three years and be available for
inspection (Reg. 18.6)
Bunker supplier must provide a Bunker Delivery Note (BDN)
• BDN to be retained for 3 years
• BDN to include:
– Name and IMO number of receiving ship
– Port and Date of commencement of delivery
– Name, address and telephone number of fuel supplier
– Product name and Quantity
– Density
– Sulphur content (actual)
– Declaration signed by supplier that the fuel oil conforms with Annex VI
A declaration that fuel supplied meets Regulation 14 and 18 requirements

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
44

Regulation 18 – Fuel Oil Quality
Fuel oil sample:
• Representative sample to be provided by the bunker
supplier
• Sample to be sealed and signed by the supplier’s
representative and the master or officer in charge of
the bunker operation
• Sample to be kept on board until the fuel oil is
substantially consumed but in any case for not less than
1 year from time of delivery
• National Authorities to regulate suppliers to ensure
their responsibilities for compliance
45

Local suppliers of fuel oil
• Parties are required to:
– maintain a register of local suppliers of fuel oil
(Reg.18.9.1)
– require local suppliers of fuel oil to provide a certified
BDN and sample (Reg.18.9.2), and retain a copy of the
BDN for 3 years (Reg.18.9.3)
– take action against local suppliers of fuel oil
(Reg.18.9.4)
– inform the Administration of a ship when the ship is
found to be non-compliant (Reg.18.9.5)
– inform the IMO of all cases of non-compliant fuel oil
being supplied (Reg.18.9.6)

Port/Flag State Control Guidelines
Parties are required to:
– inform the Party or non-Party under whose jurisdiction the BDN was
issued in cases of delivery of non- compliant fuel oil (Reg.10.1)
– ensure non-compliant fuel oil is brought into compliance (Reg.10.2)
• For ships on scheduled services with frequent and regular port calls
Administration can provide alternative procedure to retaining on board
BDN (Reg.11)
Enforcement – port State control
• Resolution MEPC.181(59) adopted 17 July 2009
• Identifies key compliance issues:
– Documentation - IAPP, EIAPP, BDN’s
– Compliance with SOx limits – fuel record book/EGS
– Compliance with engine limits for NOx
– Compliance with ODS provisions – ODS record book
– VOC management plan (if required)
– Type approval certificate for incinerator
47

ANY QUESTION?
THANK YOU!
49

MARPOL Annex VI and Emissions Control

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