MARPOL ANNEX VI AMEDMENTS
PRACTICAL CONSEQUENCES
INTERTANKO
Latin American Panel
Cancun
October 28/29, 2008
AMENDMENTS TO MARPOL Annex VI
2010
GLOBAL ECA
S cap
S cap
4.50%
1.00%
2011
2012
3.50%
2015
2016
2020/2025 0.50%
Tier II
-----
Tier III
ECA only
-----
yes
---------
0.10%
---- yes
AMEDMENTS
• New regulation on SOx and PM
• Primary compliance through fuel
• Alternative methodologies (e.g. scrubbers)
accepted as Equivalent Measures (first to be
approved by Administrations)
• Marine fuel oil quality to be further improved
• No measures on ships that do not receive
adequate supply
• if BDN data is challenged by PSC or test
results - Guidelines how to assess compliance
• NOx Tier I on large engines from the 1990s
• NOx Tier II and Tier III on new engines
GENERAL ASSESSMENT OF THE
AMENDMENTS
• Positive but not perfect
• Positive:
– contributes to a long-term and predictable
global regulatory regime
– ensures a solid platform of requirements
– is realistic and feasible
– achieves a global, long-term and positive
reduction of air emissions from ships
• BUT practical consequences need to be
carefully assessed
IMO & CARB SULPHUR
REQUIREMENTS
MEPC 57 IMO & CARB Fuel-Sulfur Content Limits
Equivalent methods may be used as alternative
5
Sulfur %
4.5
4
Global: 4.5 → 3.5 → 0.5
3.5
SECA: 1.5 → 1.0 → 0.1
3
2.5
Global
CARB MGO: 1,5 → 1.5 → 0.1 (DMA)
CARB MDO: 2.0 → 0.5 → 0.1 (DMB)
2
SECA
1.5
1
CARB Phase 1
CARB Phase 2
0.5
0
2000
2005
2010
2015
Year
2020
2025
Regional Requirements
- Still a potential problem
 Planned new ECA for 2013
 Could be extended to entire N. A.
 Up to 200 nm on the West Coast
 Plan to require 0.1% or 0.2% S fuels
PRACTICAL CONSEQUENCES
• Need to use 2/3 fuels per voyage for few more
years
• Need for greater and diversified (segregation)
of bunker tanks and pipelines able to receive 3
different grades of bunkers
• If not = loss of expensive grade bunkers during
fuel change over periods
• Need for two differing cylinder lube oil systems
(one for HSFO and one for LSFO/Distillate)
• Back to simple and safe uni-fuel operation
when MDO will be used on world wide basis
(2020)
PRACTICAL CONSEQUENCES
FUEL CHANGE OVER
• Risk of incompatibility between differing
grades of bunker during change over periods
(sludging problem)
• Increased average density
• Increased of average cat fines level (Al+Si)
• Fuels with reduced ignition/combustion quality
• Increased problems with chemical waste
(liquid waste with low/no sulphur used as
blend to “make” the LSFO)
• Switch from HFO to MDO in boilers (EU and
California) = Risk of human error poses safety
risks and cross contamination
LOW-SULPHUR FUEL OPERATION
Al - Si
A reduction of the low-sulphur content in HFO has seen a
corresponding increase in the abrasives content
Source: DNVPS database of 1,012 analysis results (from 1 October – 10 November 2007)
LOW SULPHUR OPERATION
ENFORCEMENT (PSC & Flag)
(today’s practice)
• Most PSC target controls on:
– Bunker Delivery Note (BDN)
– Availability of the MARPOL fuel sample
– fuel change-over recordings in log books (ships need
written fuel change-over procedures)
• Some PSC:
– requires to see commercial fuel test reports and
make a decision
– take fuel samples from service tanks
• ADVICE: only the MARPOL fuel sample is to be
used to test sulphur level
MARPOL Sample
verification test procedure
• Test of 2 sub-samples at accredited lab.
• If Δ of two results ≦ 0.07, S content is the
average of the two results
• If average is ≥ 1.58%, then non-compliant
• If average is ≦ 1.58%, then 2nd lab does
similar tests
• However compliance is only proved if the
average of the 4 results is ≦ 1.50%
ENFORCEMENT (PSC & Flag)
(today’s practice)
• Many Flags do not respond to ship
Notifications on non-compliant fuel
delivery
• Not unified interpretation for sulphur
content limit, e.g.: 1.50%, 1.54%,
1.58%....
• BUT some good news . . . .
• Ships not liable if strictly keep records
& evidence on Fuel Availability
Revised Regulation 18
• Authorities shall take all reasonable steps to
promote the availability of fuel oils to comply
with Annex VI
• If compliant fuel not available, ships not
required to delay departure or deviate from the
planned voyage
• The ship will have to notify its Administration
and the relevant port of call each time it cannot
find the compliant fuel
• The ship should present evidence/record it
attempted to buy the compliant fuel in
accordance with the voyage plan
• If evidence is provided, there should be no
measures against the ship
PRACTICAL CONSEQUENCES
Evidence/records/actions taken by ships:
(a) Bunker quotation/correspondence
(b) Voyage plan
(c) Bunker Delivery Note (BDN)
(d) Fuel Quality Test report
(e) Notification to Flag, Port Authority & PSC
(f) Report/indication that obtaining compliant fuel
will cause deviation/or undue delay
IMO Circular encouraging earlier application of new Regulation 18
FUEL OIL QUALITY
• IMO Secretariat invited ISO to consider a
revision of a marine fuel oil specification
(ISO 8217) addressing :
-air quality,
-ship safety,
-engine performance,
-crew health
possible PRACTICAL
CONSEQUENCES
• Fuel Quality better defined
• IMO may regulate quality of marine fuels
• Ship operators could share expereince
with Flags and demand assistance
• May accellerate the transit to better &
uni-fuel usage
• New Guidelines to test MARPOL fuel
sample complaince
Regulation 4 – Equivalent measures
•
An Administration may allow any alternative
method only if this is at least as effective in
terms of emissions reductions as the emission
reductions by using LSFO
• This means the Administration (and not the
ship) have to acknowledge that alternative
methods:
– have equivalent efficiency in terms of SOx, PM &
NOx
– do not harm the environment
– operate within the requirements of the IMO
guidelines
PRACTICAL CONSEQUENCES
• Positive outcome for ship operators
• Adminstrations and not ships
responsible to asses the efficiency and
the reliability of the alternative measures
• Adminstrations and not the ships
responsible that certified alternatives do
not harm the environment
NOx emissions – Pre-2000 engines
”Upgrade Methodology”
• Retroactive measures on engines:
– installed onboard ships constructed
between 1 Jan 1990 and 31 Dec 1999
– power output > 5,000 kW; and
– per cylinder displacement at or > 90 litres
• NOx emissions at Tier I level
• If the engine already meets Tier I NOx
emission limits, simple certification is
sufficient
NOx emissions – Pre-2000 engines
Upgrade Methodology
• If the engine does not meet the Tier I NOx
emission limitations, it is subject to measures:
– ONLY if there is an upgrading system certified by a Party
to MARPOL Annex VI
– ONLY if it certifies that such a system reduces the
emissions of that particular engine to Tier I limits
– the upgrading system is considered commercially
available 12 months after a Party to MARPOL Annex VI
deposits the notification on certification to IMO
– upgrade at the ship’s first renewal survey after the
upgrading system becomes commercially available
– in case the upgrading system is not available at the time
of completion of the renewal survey (ship owner has to
document that), the flag would give an extension until
the next Annual Survey
NOx emissions – Pre-2000 engines
• The upgrading system should not
– decrease the engine rating by more than 1%,
– increase fuel consumption by more than 2%
– have other adverse effect on the durability or
reliability of the engine
• Upgrading to an acceptable cost/benefit
Cost of approved method x 10**6
Ce =
P(kW) x 0.768 x 6000 hr/yr x 5 years x Δ NOx (g/kWh)
Ce < 375 SDR/metric ton of NOx reduction;
SDR = Special Drawing Rights; 1 SDR = US$ 0.632
Ce < $237/metric ton of NOx reduction
NOx Kits – Example for
IMO max. retrifitting costs (US$)
Power
(kW)
Re
duction
10%
20%
30%
40%
50%
1.7
3.4
5.1
6.8
8.5
5,000
46,414
92,828
8,000
74,263
148,525 222,788 297,050 371,313
12,000
111,394 222,788 334,181 445,575 556,969
15,000
139,242 278,484 417,727 556,969 696,211
(g/kWh)
139,242 185,656 232,070
NOx Kits – IMO Max. Costs (US$)
NOx emissions – Tier II (new engines)
• Tier II standards (emission reductions
related to Tier I limits):
– 15.5% reduction (engines with n<130 rpm)
(i.e. 14.36 g/kWh)
– reductions between 15.5% and 21.8%
depending on the engine’s rpm (engines with
130 rpm < n < 2000 rpm)
– 21.8% reduction (engines n > 2000 rpm) (i.e.
7.66 g/kWh)
• Applies to engines installed on ships
constructed on and after 1 January 2011
NOx emissions-Tier III (new engines)
• Tier III standards – 80% reductions from Tier I
limits, applicable when ships in ECA only
• Tier III limits apply to engines:
– installed on ships constructed on & after 1 Jan 2016
– power output of > 130 kW
(but engines between 130 kW – 750 kW may be exempted by
the Administration)
• Outside ECAs - Tier II limits only
• Emission levels for Tier III are as follows:
– 3.40 g/kWh (engines with n<130 rpm)
– 9*n(-0.2) g/kWh (engines with 130 rpm < n < 2000 rpm)
– 1.96 g/kWh (engines n > 2000 rpm
PRACTICAL CONSEQUENCES
• Not a responsibility for ship operators
• Tier III compliance with SCRs (latest news –
possible solution through in engine technology)
• If compliance through SCR only
– existing SCR technology not efficient at low engine loads
– compliance might not be achieved in ECAs (close to port,
through estuaries and straits ships slow down) because the
engine runs at a lowwe load
• Engine manufacturers to demonstrate compliance
• Class/Administration to certify
• BUT, in the long run, how would be Tier II
compliant ships (delivered between 2011 and
2016) be treated in ECAs?
• Good advice: if possible, plan for Tier III compliant
ships as from 2011
Regulation 15
Volatile Organic Compounds
• All tankers carrying crude oil shall have
on board an approved VOC-Management
Plan describing all the procedures the
ship is applying in order to minimize the
emissions of VOC
• Apart from that, there is no requirement
for equipment or technical installations
to limit the emissions
• INTERTANKO works with DNV to a draft
VOC Management Plan model to be
submitted to IMO
OUTCOME ON MARPOL ANNEX VI
THANK YOU VERY MUCH