MARPOL Annex VI – Air Pollution

MARPOL Annex VI – Air Pollution

Marpol Annex VI – Air Pollution
Agenda Presentation of MARPOL Annex VI NOx emission compliance NOx certification of diesel engines 1st step: pre-certification 2nd step: initial survey onboard 3rd step: periodical surveys onboard IAPP Certificate

Presentation of MARPOL Annex VI
Provides regulations for the prevention of air pollution from ships, Will enter into force on 19 May 2005, Applies to all ships of 400 gross tonnage and above and to offshore units built on or after 19 May 2005, Ships built before 19 May 2005 are to be certified not later than the first scheduled drydocking after 19 May 2005, but in any case by 19 May 2008, The compliance of the ship with Annex VI will be marked by the issuance of an IAPP Certificate.

MARPOL Annex VI covers Ozone depleting substances, Nitrogen oxide emissions from diesel engines, Sulphur oxide emissions from ships, Volatile organic compound emissions from tankers, Shipboard incineration, Fuel oil quality.

Ozone depleting substances (ODS): Regulation 12 New installations containing ODS prohibited on all ships ODS are defined in the Montreal Protocol on Substances that deplete the Ozone Layer. The following ODS may be found on board ships: halon 1211, halon 1301, halon 2402 CFC-11, CFC-12, CFC-113, CFC-114, CFC-115 Deliberate emission of ODS during operation, maintenance, repair, etc. are prohibited. Hydro fluorocarbons permitted until 1 January 2020.

Ozone depleting substances (ODS): BV surveyor actions The crew should have been informed about the ODS emission restrictions. IAPP certificate: Paragraph 2.1 is to be filled in.

NOx emissions from Diesel engines: Regulation 13 Applies to all Diesel engines With a power > 130 kW Installed on a ship built on or after 1 January 2000 Or built on or after 1 January 2000 and replacing an existing engine (or added to existing engines) Or which undergo a substantial modification on or after 1 January 2000 Or the MCR of which is increased by more than 10% after 1 January 2000

NOx emissions from Diesel engines: Regulation 13 Does not apply to the following engines: Emergency diesel engines Engines installed in lifeboats Other engines used solely in case of emergency

NOx emissions from Diesel engines: BV surveyor actions Will be detailed later.

SOx emissions from the ship: Regulation 14 General requirement The sulphur content of any fuel oil used onboard is not to exceed 4,5% m/m Applies to the whole ship, regardless of the type of combustion machinery or fuel grade. In SOx Emission Control Areas (SECA) The sulphur content of fuel oils used within SECAs is not to exceed 1,5% m/m. Alternatively, exhaust gas cleaning systems or equivalent means can be used to reduce SOx emissions below 6.0 g/kWh

SOx emissions from the ship: Regulation 14 (cont.) Present situation of SECAs Baltic Sea from 19 May 2006, North Sea probably from end of 2007 Procedure to be followed when entering a SECA Where several types of fuel oils are used, fuels systems with sulphur content exceeding 1,5% m/m are to be fully flushed before entering the SECA. All parameters related to the fuel changeover are to be recorded.

SOx emissions from the ship: BV Surveyor action When the ship operates in a SECA check that: As documented by the bunker delivery notes (see regulation 18), the fuel oil sulphur content is below 1,5% m/m. or An approved exhaust gas cleaning system is provided. An other approved technology to reduce SOx emissions below 6,0 g SOx/kWh is used.

Shipboard incineration: Regulation 16 Incinerators installed on board a ship on or after 1 January 2000 are to be type approved in accordance with the provisions of IMO Resolution MEPC.76(40) : Standard Specification for Shipboard Incinerators. Operating manual specifying how to operate the incinerator is to be kept onboard. Incineration of certain substances is prohibited (cargo residues, PCBs, etc.). Personnel responsible for the operation is to be trained.

Shipboard incineration: BV Surveyor action Check that the operating manual of the incinerator is available onboard. Check that the personnel responsible for the operation is properly trained.

Fuel oil quality: Regulation 18 The “appropriate authorities” will have to maintain a register of local fuel oil suppliers. Details of fuel oils used onboard shall be recorded by means of a bunker delivery note containing the following information: Name and IMO number of the 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) A declaration signed and certified by the fuel oil supplier’s representative that the fuel oil supplied is in conformity with regulation 14 (1) or (4) (a) related to sulphur content and regulation 18 (1) related to fuel oil elaboration process (see Appendix V)

Fuel oil quality: Regulation 18 (cont.) Bunker delivery notes are to be kept onboard the ship for a period of 3 years after the fuel oil has been delivered onboard. The bunker delivery note shall be accompanied by a representative sample of the fuel oil delivered. The sample is to be kept onboard until the fuel oil is substantially consumed , but in any case for at least 12 months from the time of delivery. Guidelines for the sampling are given in Resolution MEPC.96(47).

Fuel oil quality: Regulation 18 (cont.) BV Surveyor action Should be limited to the verification of the bunker delivery note to check the sulphur content of the fuel oil used when the ship operates in SOx emission control areas.

NOx emission compliance
1 - General “NOx” means NO and NO2, which are formed during fuel combustion. NOx emissions from diesel engines only are considered. NOx emissions from marine diesel engines account for approximately 17% of global NOx emissions produced by fuel combustion. Other sources are considerably lower (about 2 g/kWh for boilers and 5 g/kWh for gas turbines vs. 10 to 15 g/kWh for diesel engines). NOx has harmful effect on the environment (acidification, formation of ozone, adverse health effects).

2 – NOx-influencing parameters NOx emissions are influenced by the combustion process. When the combustion temperature and duration increase, the amount of NOx formed increases. Higher peak pressure and compression ratio result in higher NOx emission levels. NOx-influencing parameters include: Injection parameters (timing, nozzle, pump, fuel cam, injection pressure for common rail systems). Combustion chamber (cylinder head, piston, cylinder liner, compression ratio, valve timing). Charge air system (turbocharger, charge air cooler).

2 – NOx-influencing parameters (cont.) Equipment to reduce NOx emissions: Direct water injection Charge air humidification Emulsified fuel (fuel / water emulsion) Exhaust gas recirculation Selective catalytic reduction (injection of urea solution)

NOx certificate of diesel engines
1st step: pre-certification ENGINE GROUP OR FAMILY SPECIFICATION TECHNICAL FILE ON-BOARD NOx VERIFICATION PROCEDURE CONFORMITY OF PRODUCTION DOCUMENT REVIEW PRE-CERTIFICATION SURVEY ISSUANCE OF EIAPP OR STATEMENT OF COMPLIANCE

STATEMENT OF COMPLIANCE ENGINE INTERNATIONAL AIR POLLUTION PREVENTION (MEPC / Circ. 344 of 19 November 1998) Issued under the provisions of the Protocol of 1997 to the International Convention for the Prevention of Pollution from Ships, 1973, as modified by the Protocol of 1978 related thereto (hereinafter referred to as “the Convention”) No NOx/2000/76P by BUREAU VERITAS Engine Manufacturer Model number Serial number Test cycle(s) Rated Power (kW) and Speed (RPM) Engine Approval number SSANGYONG Heavy Industries Co., Ltd. MAN B&W 9L28/32H SB9L D2 1890 kW x 720 rpm MOT 4/371/5 This is to certify : That the above-mentioned marine diesel engine has been surveyed for pre-certification in accordance with the requirements of the Technical Code on Control of Emission of Nitrogen Oxides from Marine Diesel Engines made mandatory by Annex VI of the Convention ; and That the pre-certification survey shows that the engine, its components, adjustable features, and Technical File, prior to the engine’s installation and/or service on board a ship, fully comply with the applicable regulation 13 of Annex VI of the Convention. This Statement is valid for the life of the engine subject to surveys in accordance with regulation 5 of Annex VI of the Convention, installed in ships under the authority of this Government. Issued at PARIS LA DEFENSE on 02 January 2001 (Place of issue of statement) (Date of issue) C. MAILLOT - SECRETARY (Signature of duly authorized official issuing the statement) (Seal or Stamp of the authority, as appropriate)

No NOx/2000/76P Supplement to Engine International Air Pollution Prevention Statement of Compliance (EIAPP Statement of Compliance) RECORD OF CONSTRUCTION, TECHNICAL FILE AND MEANS OF VERIFICATION In respect of the provisions of Annex VI of the International Convention for the Prevention of Pollution from Ships, 1973, as modified by the Protocols of 1978 and 1997 relating thereto (hereinafter referred to as “the Convention”) and of the Technical Code on Control of Emission of Nitrogen Oxides from Marine Diesel Engines (hereinafter referred to as the “ NOx Technical Code”) Notes : 1. This Record and its attachments shall be permanently attached to the EIAPP Statement of Compliance. The EIAPP Statement of Compliance shall accompany the engine throughout its life and shall be available on board the ship at all times. 2. If the language of the original Record is neither English nor French, the text shall include a translation into one of these languages. 3. Unless otherwise stated, regulations mentioned in this Record refer to regulations of Annex VI of the convention and the requirements for an engine’s Technical File and means of verifications refer to mandatory requirements from the NOx Technical Code. Particulars of the engine 1.1 Name and address of manufacturer : SSANGYONG Heavy Industries Co., Ltd. 1.2 Place of engine build : as above 1.3 Date of engine build : April 2000 1.4 Place of pre-certification survey : as above 1.5 Date of pre-certification survey : April 2000 1.6 Engine type and model number : MAN B&W 9L28/32H 1.7 Engine serial number : SB9L 1.8 If applicable, the engine is a parent engine x or a member engine of the following engine family or engine group : L 28/32H, as per annexed list 1.9 Test cycle(s) (see chapter 3 of the NOx Technical Code) : D2 1.10 Rated Power (kW) and Speed (RPM) : 1890 kW x 720 rpm 1.11 Engine approval number : MOT 4/371/5 1.12 Specification(s) of test fuel : MDO (ISO-F-DMC)

1.13 NOx reducing device designated approval number (if installed) : not applicable 1.14 Applicable NOx Emission Limit (g/kWh)(regulation 13 of Annex VI) : 12.1 g/kWh 1.15 Engine’s actual NOx Emission Value (g/kWh) : 10.7 g/kWh (at 110% of the rated power) Particulars of the Technical File 2.1 Technical File identification/approval number : MOT 4/371/5 NOx 2.2 Technical File approval date : 02 January 2001 The Technical File, as required by chapter 2 of the NOx Technical Code, is an essential part of the EIAPP Statement of Compliance and must always accompany an engine throughout its life and always be available on board a ship Specifications for the On-board NOx Verification Procedures for the Engine Parameter Survey On-board NOx verification procedures identification/approval number : MOT 4/371/5 NOx On-board NOx verification procedures approval date : 02 January 2001 The specifications for the on-board NOx verification procedures, as required by chapter 6 of the NOx Technical Code, is an essential part of the EIAPP Statement of Compliance through its life and always be available on board a ship. THIS IS TO CERTIFY that this Record is correct in all respects Issued at PARIS LA DEFENSE on 02 January 2001 (Place of issue of statement) (Date of issue) C. MAILLOT - SECRETARY (Signature of duly authorized official issuing the statement) (Seal or Stamp of the authority, as appropriate)

Engine Approval number
NOx certificate of diesel engines Annex to Statement of compliance N° NOx/2000/76P MAN B&W L28/32H GROUP LIST OF MEMBERS Engine Type Nominal rated power (kW per cylinder) Rated speed (rpm) Certified power range Engine Approval number 5L28/32H 210 720 168 to 231 MOT 4/371/1 6L28/32H MOT 4/371/2 7L28/32H MOT 4/371/3 8L28/32H MOT 4/371/4 9L28/32H MOT 4/371/5* *parent engine of the group

2nd step: initial survey onboard Purpose : after the pre-certification of the engine, determine to what extent the engine has been subjected to further adjustments and / or modifications which could affect the NOx emissions. See NOx Technical Code, § Scope of the inspection : check the possible modifications undergone by the engine further to the pre-certification by means of the methods allowed by the Code, § 2.1.2: On-board engine parameter check method On-board simplified measurement method

2nd step: initial survey onboard

On-board engine parameter check method (see NOx Technical Code, Chapter 6) This method includes: A document inspection of engine parameters (record book) to check that they are within the allowable range specified in the engine Technical file. Engine parameters include NOx-influencing components and settings, and operating values (like cylinder peak pressure, exhaust gas temperature) which are related to the NOx emission performance.

On-board engine parameter check method (cont.) (see NOx Technical Code, Chapter 6) The record book of engine parameters contains the description of all changes affecting the engine parameters, adjustments, parts replacements or modifications. The record book is to be kept available on board together with the Technical File and On-board NOx verification procedures.

On-board engine parameter check method (cont.) (see NOx Technical Code, Chapter 6) An inspection of engine components and adjustable features in addition to the documentation inspections. It shall be verified that the adjustable features are within the allowable range specified in the Technical File. The surveyor can check one or all of the components, settings or operating values. Where adjustments / modifications have been made, the surveyor has to check that they fall within the approved range as specified in the Technical File.

On-board engine parameter check method (cont.) (see NOx Technical Code, Chapter 6) Where the adjustments / modifications fall outside the approved range, the situation is that of a “substantial modification” and complete NOx measurement are normally required.

On-board simplified measurement method (see NOx Technical Code, Chapter 6) This method is derived from the procedure for NOx emission measurements on a test bed. Main simplifications are: HC measurements not required. Engine torque may be estimated by means other than direct measurement (voltage / amperage measurement for generating sets, propeller curve with engine speed measurement). For the fuel consumption, the results from the test bed measurements can be used.

On-board simplified measurement method (cont.) (see NOx Technical Code, Chapter 6.3) Less parameters to be measured Test fuels: heavy fuel oil of RM-grade according to ISO 8217, 1996, may be used. Deviations from the engine load points corresponding to the concerned test cycle can be considered. Allowances from 10% to 15% of the applicable NOx limit will be applied.

3rd step: periodica l surveys onboard Periodical surveys will have to be carried out at intervals specified by the flag administration, but not exceeding 5 years. One intermediate survey is to be carried out during the period of validity of the IAPP Certificate. See MARPOL Annex VI, reg. 5 (c).

3rd step: periodica l surveys onboard

Scope of the periodical surveys onboard Scope of the inspection : similar to the initial survey, i.e. check the possible modifications undergone by the engine further to the previous on-board survey. Method of survey : According to the Code, § 2.1.2: On-board engine parameter check method (already described) On-board simplified measurement method (already described) On-board direct measurement and monitoring method

Direct measurement and monitoring method This method is described in IMO Resolution MEPC.103(49): Guidelines for on-board NOx verification procedure – direct measurement and monitoring method This method is similar to the test bed measurement method and simplified measurement method. It involves the installation of a fixed or portable emissions measurement / recording system, allowing a continuous or intermittent monitoring. The measurement / recording system should be type-approved by BV. No Direct measurement and monitoring systems approved to date.

Direct measurement and monitoring method (cont) Analysers are to be checked and adjusted in accordance with the NOx Technical Code. The main difference in comparison with bed and simplified measurement method is that different combinations of weighting factors can be used, depending on the test cycle considered. See Appendix 2 of the Resolution. To demonstrate compliance with the NOx Technical Code, the data are to be taken during the last 30 days. Data may have been collected in several occasions when the engine load corresponds to that required by the Resolution. Data are to be retained on-board for at least 3 months.

Direct measurement and monitoring method (cont) An on-board monitoring manual is to be submitted to BV for approval. The surveyor will check: The data obtained from the measurements (may be presented in electronic format) The measuring equipment, including checking and adjustment are in accordance with the manual. Of course, there will be no attendance of the Surveyor to the measurements.

Direct measurement and monitoring method (cont) Main benefits of the direct measurement and monitoring method are for the owner: It allows a continuous record of the engine emissions It does not require any disruption of the vessel operations It reduces survey fees!

IAPP Certificate This item is to be filled in when no modifications or minor modification have been made to the engine

IAPP Certificate This item is to be filled in case of major conversion of the engine: substantial modification, or power increase > 10%

IAPP Certificate This item is to be filled in when the engine is fitted with an exhaust gas cleaning system or other equivalent method.

IAPP Certificate This item is to be filled in when the engine is fitted with a NOx monitoring and recording device.

Air emissions: Cap on NOx (MARPOL Annex VI Reg 13)
Engine fitted on a ship built at date D: Outcome of MEPC58 1/1/2000 ≤ D < 1/1/2011 Tier I 1/1/2011 ≤ D < 1/1/2016 Tier II 1/1/2016 ≤ D Tier III in ECA Tier II elsewhere “existing engines” 1/1/1990 ≤ D < 1/1/2000 cylinders ≥ 90 l & power > 5,000kW Revised MARPOL Annex VI will enter into force 1st July 2010 Engine rpm N < 130 130 ≤ N < 2000 N ≥ 2000 Tier I Current Reg 13(3)(a) 17 g / kWh 45 N-0.2 g / kWh 9.8 g / kWh Tier II ~ 80% Tier I 14.4 g / kWh 44 N-0.23 g / kWh 7.7 g / kWh Tier III ~ 20% Tier I 3.4 g / kWh 9 N-0.2 g / kWh 2 g / kWh

How to reduce NOx emissions?
Humidification (water injection in charge air system) Water / fuel emulsion Fuel quality Natural gas Optimization of combustion process Injection timing retard Injection rate profile tuning (common rail technology) Compression ratio Charge air temperature and pressure Exhaust gas recirculation Direct water injection Selective catalytic reduction (SCR) Before combustion Engine modification After combustion

Revised MARPOL Annex VI will enter into force on 1st July 2010
Air emissions: Cap on Sulphur content of fuels (MARPOL Annex VI Reg 14) Revised MARPOL Annex VI will enter into force on 1st July 2010 General requirements sulphur content ≤ 4,50 % before January 2012 sulphur content ≤ 3,50 % on or after 1 January 2012 sulphur content ≤ 0,50 % on or after 1 January 2020, (subject to a feasibility review to be completed not later than 2018 in order to respond to objections raised by the refining industries. Should the review conclude negatively, the effective date would be 1 January 2025.) In ECA (emission control areas) sulphur content ≤ 1,5% before March 2010 (or exhaust gas cleaning system with total emission of SOx ≤ 6 g SOx/kWh). sulphur content ≤ 1 % on or after March 2010 (or exhaust gas cleaning system with total emission of SOx ≤ 4 g SOx/kWh). sulphur content ≤ 0.1 % on or after 1 Jan (or exhaust gas cleaning system with total emission of SOx ≤ 0.4 g SOx/kWh).

UE / IMO comparison relating to fuel oil sulphur contents
IMO and UE regulations relating to SOx UE / IMO comparison relating to fuel oil sulphur contents IMO General IMO ECA EU ECA EU At berth 01/01/2012 01/01/2020 01/03/2010 01/03/2015 1% 0.1% 0.5% 3.5% 1.5% 4.5% 0.5% ? 01/01/2010

Exhaust gas cleaning systems
How to reduce SOx emissions? Exhaust gas cleaning systems Sea water scrubber open loop system sulphur neutralized by water alkalinity. Fresh water scrubber closed loop system uses NaOH zero discharge in enclosed area Guidelines for exhaust gas cleaning system adopted by MEPC 57 on 4 April 2008

Outcome of MEPC 59 (12 – 17 July 2009)
Approval of amendments to Annex VI/Marpol to designate specific portions of the coastal waters of the United States and Canada as an Emission Control Area (ECA) Expected to enter into force on 1 July 2010 Control of Emissions of nitrogen oxides (NOx), sulphur Oxides (Sox) and particulate matter Reminder: Baltic Sea Area and North Sea (incl English-French Channel) are currently listed as “SECA” for the Control of Sox Emissions Adoption of guidelines to assist the implementation of the revised Annex VI/Marpol: Guidelines for the sampling of fuels Revised Guidelines for monitoring the worldwide average Sulphur Content Revised Guidelines for Exhaust Gas Cleaning Systems Guidelines for the development of VOC Management Plans Guidelines for the application of the NOx Technical Code relative to Certification and Amendments of Tier I Engines

The environmental matters present three characteristics:
Green House Gases World CO2 emissions by sector (106 tonnes of CO2) The environmental matters present three characteristics: They are unavoidable, They are generally painful, They are often controversial.

Efficient designs & operations
Waste heat recovery Heat recovery: - from exhaust gases - from charge air cooling system - from cylinder cooling system Efficiency gain: x 1.1 (+ 10%)

MEPC 59: Interim Guidelines For Voluntary Verification of EEDI (Energy Efficiency Design Index - New Ships) Two-Stage Verification Process: Preliminary verification, at design stage Final Verification of the Attained EEID, at the sea trial

MEPC 59: Guidance for the Development of a Ship Energy Efficiency Management Plan (SEEMP)
Suggested best practices Fuel Efficient Operations Improved voyage planning (IMO Res A.893(21)) Weather routeing Just in time (Port communication, speed selection) Speed optimization Optimized shaft power Optimized ship handling Optimum trim / Ballast Optimum propeller and propeller inflow considerations Optimum use if rudder and heading control systems Hull Maintenance/Docking intervals

MEPC 59: Guidance for the Development of a Ship Energy Efficiency Management Plan (SEEMP)
Propulsion System Propulsion system maintenance Waste oil recovery, improved fleet management, energy management, etc…

MARPOL Annex VI – Air Pollution

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