Air Emissions from Ships

Society is driving the requirement for ships to reduce harmful air emissions from engine exhausts

Governing Regulations MARPOL Annex VI entered into effect in 2005 Baltic Sea - SECA from May 2006 North Sea - SECA in November 2007 Europe Sulphur Directive (1999 & Rev) governs inter alia emissions in port (0.1% S at berth) California (CARB) new regulations which took effect Jan 2007 Various ports - local regulations on Ship Emissions, which are inhibiting future expansion/development - introducing differentiated port fees Of particular concern to tramp sectors, trading internationally, lifting bunkers in ports worldwide

4 MARPOL – Annex VI Control of Air Pollution from Ships and its Current Revision process

Air Emissions from Ships Covered by Annex VI –Oxides of Nitrogen (NOx) – create Ozone –Sulphur Oxides (SOx) – create acidification –Hydrocarbons (HC) – gas, soot and some particulates –Volatile Organic Compounds (VOC) –Refrigerant Gases Not covered (currently) by Annex VI –Carbon Dioxide (CO 2 ) –Carbon Monoxide (CO) Engine exhaust gases are dependent upon engine type, engine settings and fuel type

The Regulations in Annex VI There are 19 Regulations but the following Regulations impact Vessel operation : –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

IMO Annex VI revision process MEPC 53 (July 2005) – Decided Annex VI be revised MEPC 54 (March 2006) – Proposals for revision. Delegated work to BLG Sub-Committee BLG 10 (April 2006) – Initial review of proposals and documents (over 30 documents) Two correspondence groups (April – October 2006) Intersessional Meeting (November ) – discussion of key issues and draft proposals BLG 11 (April 2007) – finalize draft proposals for revised Annex VI, the NOx Code and related Guidelines MEPC 56 (July 2007) & MEPC 57 (March 2008) - consider and approve(?) the revised texts Target date for Entry in to Force : 2010/12

Many proposals for significant amendments to Annex VI Lower limits for SOx & NOx emissions SECAs with lower S cap (1% or 0.5%) NOx emission limitation on existing engines, particularly those installed after Jan NECAs – NOx controlled areas Restriction on CO 2 emissions Restriction on Particulate Matters (PM) emissions Restriction on VOC emissions from cargo oil tanks

Possible Guiding Principles –prevent fragmented regulations –promote establishment of a global standard for at sea, coastal and at berth operations (maybe no SECAs) –international standards via IMO –regulations based on a fuel standard rather than an emissions performance standard, and thus reduce the onus of responsibility on the owner/operator for verification and compliance (sympathy for use of clean fuels / distillates only)

Guiding Principles Executive Committee (June 2006) – Principles for an INTERTANKO position: –ensure a solid platform of requirements –be realistic and feasible –seek a long term and positive reduction of air emissions from ships, and –contribute to a long term and a predictable regulatory regime

Owners’ Concerns Multitude of differing requirements Additional requirements for multi-fuel usage

EXISTING SECAs NOV MAY 2006 SOURCE: /

Owners’ Concerns Expanded number of SECAs, some with different requirements Proliferation of port, state and regional requirements – often conflicting Installation/retrofitting of: - multi-fuel tanks and associated systems - scrubber technologies, exhaust filters, etc. (still to be proven) Onboard handling and disposal ashore of toxic wastes from exhaust gas scrubbing – in addition to existing sludge handling problems Further fuel treatment processing Operational and safety concerns during fuel switchovers Additional fuel log record keeping and reporting Onus of responsibility falling solely on the owner/operator

Owners’ Concerns Who bares responsibility for monitoring, verification and compliance ? Owner for: Combustion process Exhaust gas emission standards Disposal of by-products OR Fuel supplier for: Quality of fuel supplied

Alternative Approaches Do nothing – retain HFO for deep sea Extend SECAs Global SECA Establish local SECAs Establish NECAs Use technological solutions – catalytic converters, scrubbers and/or filters Burn distillates close to shore Cold ironing Emissions trading

An Approach FOR DISCUSSION: The use of distillate fuels, with a global S content cap introduced using a two tiered programme, as follows:The use of distillate fuels, with a global S content cap introduced using a two tiered programme, as follows: –from [2010], a maximum of 1.00% S content –for ships’ engines installed on and after [2015], a maximum [0.50]% Sulphur content A Global Sulphur Emission Control AreaA Global Sulphur Emission Control Area If the above two issues were considered feasible, then the provisions for checking and monitoring compliance with Regulation 14 and 18 should be revised accordingly.If the above two issues were considered feasible, then the provisions for checking and monitoring compliance with Regulation 14 and 18 should be revised accordingly.

Alternative Approaches ITEMS FOR DISCUSSION include: Future production of low sulphur fuels & time frame Proving of / reliability of SCR and scrubber technologies Costs of extra bunker tanks & associated systems Costs of manifold modifications / sampling Costs of additional maintenance Means of disposing of wash water and scrubbed by- products Suitability of blended fuels Net benefits Future costs of low sulphur HFO/IFOs

DISTILLATES - ADVANTAGES reduces all types of air emissions from ships, including PMreduces all types of air emissions from ships, including PM reduces the bunker consumption (by weight) by 5% to 10%reduces the bunker consumption (by weight) by 5% to 10% eliminates the need of retrofitting of additional bunker storage capacity and associated pipingeliminates the need of retrofitting of additional bunker storage capacity and associated piping eliminates current onboard fuel treatment plants and significantly reduces onboard generated ER waste and exposure of the engines to damaging materialseliminates current onboard fuel treatment plants and significantly reduces onboard generated ER waste and exposure of the engines to damaging materials

DISTILLATES - ADVANTAGES eliminates the need for scrubbers for the inert gas systemeliminates the need for scrubbers for the inert gas system no additional costs of installing, operating and, maintaining/repairing equipment for reducing PM and SOx emissionsno additional costs of installing, operating and, maintaining/repairing equipment for reducing PM and SOx emissions no potential losses due to delay in case of unexpected breakdown of onboard technologyno potential losses due to delay in case of unexpected breakdown of onboard technology if no SECAs, no operational burdens for ships & no associated risks when changing fuel types, lube oils and settings for the ship’s enginesif no SECAs, no operational burdens for ships & no associated risks when changing fuel types, lube oils and settings for the ship’s engines

Objective of INTERTANKO submission The main purpose of the INTERTANKO submission is to "present issues that merit further discussion by the IMO Working Group when considering the revision of Annex VI of MARPOL" INTERTANKO believes that it is important that there is open debate at the international level on the subject of how best to meet rapidly changing expectations for lower ship emissions and that there should be full and frank discussion of the various solutions possible.

INTERTANKO Approach ITEMS FOR DISCUSSION include: Future production of distillates & time frame Confirmation of switch-over implications Costs of engine conversions Net benefits Future costs of distillates

ONE Approach for CALIFORNIA Environmental achievements 2006 Maersk Line announced a pilot environmental initiative that annually reduces vessel-related emissions from the company’s fleet that calls the ports of Los Angeles and Oakland, USA. Maersk Line has voluntarily switched to low-sulphur diesel on the main and auxiliary engines of its vessels when they are within 24 miles of the port and alongside. Maersk Line projects a 73% annual reduction in particulate matter and a 92% reduction in sulphur dioxide (SOx).

Options for SOx and PM Emissions (Revisions to Annex VI – InterSessional Nov 2006) ANo change BGlobal S cap unchanged SECA cap 1.0% [2010], 0.5% [2015] CSwitch to distillates Global S cap 1% in [2012], 0.5% [2015] C2As per C, with alternative such as exhaust gas cleaning & higher S fuel (max 4.5%) to obtain equivalent emission as in C for SOx and PM

Current position INTERTANKO encourages open debate on the options available to reduce damaging air emissions from ships and has sought to provide comprehensive solutions that are applicable on a global basis. We remain anxious that the current reviews around the world do not result in a mix of local and regional requirements that impose an onerous burden on international shipping, especially those engaged in tramp shipping - bunkering in and trading to ports around the world. We continue to stress the importance that any new requirements should take full account of all the operational and safety considerations, and should be assessed on the same basis - this latter should involve the cost and environmental implications of all the production, manufacturing, operating and waste handling aspects of the proposed system, as well as other practicalities with respect to introduction, fitting/retrofitting, etc.

For further discussion at Panel Meetings and Council pre BLG

Objective of INTERTANKO submission The main purpose of the INTERTANKO submission is to "present issues that merit further discussion by the IMO Working Group when considering the revision of Annex VI of MARPOL" INTERTANKO believes that it is important that there is open debate at the international level on the subject of how best to meet rapidly changing expectations for lower ship emissions and that there should be full and frank discussion of the various solutions possible.

INTERTANKO Approach ITEMS FOR DISCUSSION include: Future production of distillates & time frame Confirmation of switch-over implications Costs of engine conversions Net benefits Future costs of distillates

Further information

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

Proposed Revisions of Regulation 14 - SOx Reduction of SOx emissions –Reduction of the Global Cap – e.g. to 3.00% –Reduction of the SECA Cap – e.g. to 1.00% or 0.50% Correction for the reporting and measurement standard to two decimal places for Sulphur content (Bunker Delivery Note criterion).

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.

Proposed Revisions of Regulation 13 - NOx Tiered approach to further NOx reductions – Tier 2 from date of revisions coming into force , and Tier 3 from 2015 Lower limit NOx emissions ( % reduction discussed for first tier – 2010) Further NOx emission limitation on all existing engines, particularly those installed after Jan NECAs – NOx emission control areas (Tier 3 levels for these areas?)

New Parameter for Air Pollution Control Particulate Matter Emission control What are these Particulates? –Sulphates from SOx –Nitrates from NOx –VOC from uncombusted hydrocarbons –Heavy Metals e.g. Vanadium, Nickel, Aluminium, Sodium, Calcium, Zinc; from Heavy Fuel oil and Lube Oil –Soot – from the aromatics in heavy fuel oil

Particulate Matter Regulation and Control Methods At present this subject matter has not been fully debated within the working group Issues to be confronted: –Size of the Particulate to be regulated – 10 micron or 2.5 micron –Extent of limitation of Particulate emission –Methods for control of Particulate emissions – e.g. Scrubbers and/or Filters –Storage and Disposal of Particulates –Control and verification of reduced emissions

Current 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 taken for further examination. –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 0 C and Sulphur content % m/m A declaration that fuel supplied meets Regulation 14 and 18.

Regulation 18 – Fuel Oil Quality Fuel Oil Sampling A sealed sample meeting the requirements in associated guidelines has to given 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) 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