Guidance Notes on the Prevention of Air Pollution From Ships

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GUIDANCE NOTES ON

PREVENTION OF AIR POLLUTION

FROM SHIPS

MARCH 1999

American Bureau of Shipping

Incorporated by Act of the Legislature of

The State of New York 1862

Copyright © 1999

American Bureau of Shipping

Two World Trade Center, 106t h

FloorNew York, NY 10048 U.S.A.



These Guidance Notes are intended to address sources of air pollution from ships and other marine

structures, and options for prevention and/or reduction of such emissions. ABS assumes no

responsibility for the use of or failure to use these Guidance Notes. The Guidance Notes provide

information for consideration in the design and operation of ships both before and after entry into

force of Annex VI of MARPOL 73/78 on Regulations for the Prevention of Air Pollution from Ships.

Nothing in these Guidance Notes shall be deemed to relieve any naval architect, designer, builder,

owner or other entity or person of the need to exercise professional judgement, nor of any warranty,expressed or implied. Nothing in these Guidance Notes replaces or alters any IMO Guidelines or the

statutes and regulations of the flag Administrations.



FOREWORD

in September 1997 a Diplomatic Conference was held at the international Maritime Organization

(IMO) in London which resulted in the adoption of a sixth Annex to the International Convention for

the Prevention of Pollution from Ships, 1973, as modified by the Protocol of 1978 relating thereto

(MARPOL 73/78). Annex VI is concerned with the prevention of air pollution from ships but, unlike

the other Annexes to MARPOL, may not always be bound by the traditional requirements for entry

into force, namely "12 months after the date on which not less than 15 States, the combined merchant

fleets of which constitute not less than 50 per cent of the gross tonnage of the world's merchant

shipping, have become parties to the 1997 Protocol".

The new Annex has been under development at the IMO for a period in excess of 8 years but the

subject of ship generated air pollution has been a topic of discussion for much longer.

Environmentalists have long argued that shipping should be held accountable for its share of global

pollution but it is only recently, as a direct result of the imposition of increasingly more stringent

land-based air pollution reduction strategies in many parts of the world, that shipping's overall

contribution to global air pollution has become more significant.

Annex VI differs from the other Annexes to MARPOL in so much as the effects of air pollution are

not necessarily evident at their point of discharge, as is the contamination of the sea by oil, chemicals,

garbage or raw sewage. Indeed, the effects of air pollution may be felt many hundreds of miles from

its source and even land-locked countries are not immune to it, as they are to other forms of marine

pollution. Because of this transboundary effect of air pollution, and the compelling need for many

countries to tackle the growing problems of its effects on human health and terrestrial/aquatic

ecosystems, the IMO has agreed to recommend the early implementation of controls to reduce both

emissions of nitrogen oxides (N0x) from new marine diesel engines, and harmful discharges from

shipboard incinerators. It has also been agreed that, in order to avoid unacceptably long delays in the

entry into force of Annex VI (as is the ease with Annex IV of MARPOL on the Prevention of

Pollution by Sewage which has still not entered into force some 25 years after its adoption), the

Marine Environment Protection Committee of the IMO will review the standard entry into force

requirements and the contents of the Annex if it has not entered into force by 31 December 2002.

The aim of these Guidance Notes is to identify those regulations in the new Annex which require to

be addressed immediately as against those which should be considered in the medium to long tern.

Types of pollution which have been omitted from the Annex, but which are being actively discussed

at the IMO are also identified as are those pollutants which are already controlled but where more

stringent controls are likely to be introduced in the medium to long term.

This guide will be of interest to owners and operators of ships, offshore platforms, drilling units and

other marine structures as wrell as surveyors, builders, designers and manufacturers of marine

equipment. It should be read in conjunction with the IMO publication "Annex VI of MARPOL73/78, Regulations for the Prevention of Air Pollution from Ships and NO x Technical Code"

available from the IMO Publications Department, Sates No. IMO-664E.

Finally, ABS would like to express its gratitude to the Institute of Marine Engineers for granting

permission to include extracts of a previous paper by Colin S. Brookman, the Author, entitled

"Exhaust Gas Monitoring" which was presented at the Tenth International Maritime and Shipping

Conference (IMAS 96) on "SHIPPING AND THE ENVIRONMENT — Is Compromise Inevitable".

Copies of the Conference Proceedings are available from the Institute of Marine Engineers reference

ISBN 0-907206-77-8.

ABS GUIDANCE NOTES ON PREVENTION OF AIR POLLUTION FROM SHIPS, MARCH 1999



GUIDANCE NOTES ON


FROM SHIPS

CONTENTS

Section

Section

compliance from 01 January 2000) 1eneral 3ew diesel engines and the NOx Technical Code 10

5ncinerators1SECTION 3 Control of Other Pollutants (Before & after entry

into force of Annex VI)31eneral53zone Depleting Substances65ulfur Oxides (SOX)67olatile Organic Compounds (VOC's)79uel Oil Quality9SECTION 4 Compliance With Annex (Including a review of

some of the options available)11 Genera 23

3hapter I - General35hapter II - Survey, Certification and Means of

Control 24

7hapter III - Requirements for Control of Emissions

from Ships5SECTION 5 The Future11 Genera 43

3uture emission controls35uture Technology51 Introduction 1ackground 3 Contents of the new Annex 4

5 Effects on Shipping 7 Why Shipping 2 Retrospective Regulatory Compliance (Early

ABSR GUIDANCE NO TES ON PREVE NTION OF AIR POLLUTION FROM SHIPS, MARCH 1999ii



SECTION 6 Conclusions1APPENDIX 1

APPENDIX 2

APPENDIX 3

APPENDIX 4

APPENDIX 5

ANNEX

APPENDIX 6

APPENDIX 7

Chapter III of Annex VI on the Requirements for

Control of Emissions From Ships5Information to be Included in the Bunker Delivery

Note (Regulation 18(3))5Notification to the Organization on Ports or

Terminals where Volatile Organic Compounds

(VOCs) Emissions are to be Regulated7Definitions9Interim Guidelines for the Application of the NOx

Technical Code3INTERIM GUIDELINES FOR THE APPLICATION OF

THE NOx TECHNICAL CODE 75Check Sheet for an Engine Parameter Check

Method 77

Useful Web Site Addresses9ivBS1 GUIDANCE NOTES ON PREVENTION OF AIR POLLUTION FROM SHIPS, MARCH 1999



ABBREVIATIONS AND SYMBOLS

(As used in the Guidance Notes)

ABSmerican Bureau of Shipping

Annex Iof MARPOL 73/78) on the Prevention of Pollution by Oil

Annex IIof MARPOL 73/78) on the Control of Pollution by Noxious Liquid Substances

in Bulk

Annex IIIof MARPOL 73/78) on the Prevention of Pollution by Harmful Substances

carried by Sea in Packaged Form

Annex IVof MARPOL 73/78) on the Prevention of Pollution by Sewage

Annex Vof MARPOL 73/78) on the Prevention of Pollution by Garbage from Ships

Annex VIof MARPOL 73/78) on the Prevention of Air Pollution from Ships

BDCottom dead center

CFChiorofluorocarbon

CFRode of Federal Regulations (US)

Circ.ircular

COarbon monoxide

COCertificate of Compliance

CO2arbon dioxide

DEesign & Equipment Sub-Committee (of the IMO)

EGRxhaust gas recirculation

EIAPPCngine International Air Pollution Prevention Certificate

EMEPo-operative Programme for Monitoring & Evaluation of Long Range

Transmission of Air Pollutants in Europe

FCCCramework Convention on Climatic Change

FPSOloating production, storage & offloading (facility)

FSUloating storage unit

gfkWhrams per kilowatt hour

GWPlobal warming potential

HAMumid air motor

HCydrocarbon

HCFCydrochlorofluorocarbon

HCI ydrogen chloride

HF ydrogen fluoride

ABS" GUIDANCE NOTES ON PREVE NTION OF AIR POLLUTION FROM SHIPS, MARCH 1999



Hg

IAPPC

IMO

ISO

kW

LNG

LRTAP

m

mlm

Mercury

International Air Pollution Prevention Certificate

International Maritime Organization

International Standards Organization

Kilowatt

Liquefied natural gas

Convention on Long Range Transboundary Air Pollution

Meter

Cubic meter

Mass per unit mass

MARPOLnternational Convention for the Prevention of Pollution from Ships, 1973, asmodified by the Protocol of 1978 relating thereto (MARPOL 73/78)

MEPCarine Environment Protection Committee (of the IMO)

mgilligram

MJegajoule

MSCaritime Safety Committee (of the IMO)

nngine speed in rpm

NH3mmonia

nmanometer

NOitric oxide

NO2itrogen dioxide

NOxitrogen oxides

02xygen

03zone

ODPzone depleting potential

PCBolychlorinated biphenyl

PFCerfluorocarbon

PMarticulate matter

ppmarts per million

PSCort State control

PVColyvinyl chloride

R11, R115 etctandard refrigerant identification numbers

rpm evolutions per minute

SCR elective catalytic reduction

viBS GUIDANCE NOTE S ON PREVE NTION OF AIR POLLUTION FROM SHIPS, MARCH 1999



SO2ulphur dioxide

SOLASnternational Convention for the Safety of Life at Sea, 1974 and its Protocol

of 1978

SOXulphur oxides

SOX ECAulphur oxides emission control area

TBNotal base number (oil)

TBTributyltin

TRechnical report

UKnited Kingdom

UNnited Nations

UNCLOSnited Nations Convention on Law of the Sea

UNFCCCnited Nations Framework Convention on Climatic Change

USAnited States of America

VECSapor emission control system

VITariable injection timing

VLCCery large crude carrier

VOColatile organic compound

ABS'' GUIDANCE NOTES ON PREVENTION OF AIR POLLUTION FROM SHIPS, MARCH 1999ii



GUIDANCE NOTES ON


FROM SHIPS

SECTION 1 Introduction

'I Background

1.1

Whilst there are many sources of air pollution in the modem world, the continuing use of fossil fuels

remains the largest single contributor to atmospheric pollution. Ever since sail gave way to

mechanical power, as the predominant method of propulsion, shipping has contributed to this

pollution; in the past this has largely been ignored because, compared to land-based sources,

shipping's contribution was considered negligible. It is only in the last ten years or so, as a direct

result of increasingly stringent abatement technology being applied ashore, that ships' emissions,particularly exhaust gases, are no longer considered insignificant.

1.3

Recent studies have indicated that ships exhaust emissions may now be responsible for up to 14% of

the worldwide nitrogen oxides (N0x ) emissions and approximately 8% of sulfur oxides (S0 x )

emissions although these figures have been disputed by the international shipping community based

on the annual consumption of bunker oil fuel which, at some 140 million tonnes, only accounts for

approximately 4% of the world's total oil fuel consumption. However, earlier publicity given to

somewhat lower estimates of NO & SO„ emissions, coupled with evidence of damage to human

health and terrestrial/aquatic ecosystems resulting from other pollutants such as Halons,

Chlorofluorocarbons (CFCs), Volatile Organic Compounds (VOCs) and the products of combustionfrom shipboard incinerators, prompted the International Maritime Organization (IMO) to place air

pollution on the agenda of the Marine Environment Protection Committee (MEPC) towards the end

of the 1980s.

1.5

After some 8 years of often passionate arguments a new Air Pollution Annex was finally adopted by

a MARPOL Diplomatic Conference in September 1997. The adoption of the Annex was by means of

the Protocol of 1997 to amend MARPOL 73/78 and, at the same time, a number of Conference

Resolutions were also adopted including four which are likely to have a profound effect on the

operation of shipping over the coming years, they are:

ABS' GUIDANCE NOTES ON PREVEN TION OF AIR POLLUTION FROM SHIPS, MARCH 1999



Section 1 introduction

3.1.5

Volatile organic compounds (VOCs), which are mainly given off during cargo operations

on certain oil, gas and chemical tankers, will only be regulated when so required by

individual Administrations for ports and terminals under their jurisdiction.

3.3

In addition to legislation on the substances noted above, the design and operation of shipboard

incinerators will be further regulated whilst the quality of fuel oil supplied to ships will also be

controlled and monitored, the combustion of sub-standard fuel being one of the prime causes of

certain types of air pollution. The provision of adequate reception facilities and application of the

new Annex to Platfouns and Drilling Rigs are also addressed. For ease of reference a copy of

Chapter [II of Annex VI, Regulations 12 through 19, is included as appendix 1 to these Guidance

Notes.

5 Effects on Shipping

5.1Unlike the three "optional" Annexes to MARPOL (III, IV & V) which have been adopted by the IMO

(only two of which have thus far entered into force), Annex VI has been introduced by means of a

Protocol and, upon entry into force, will require all Convention ships of Parties to MA.RPOL 73/78 to

be issued with an International Air Pollution Prevention Certificate. Prior to the issuance of this

statutory certificate the flag State, or a Recognised Organization acting on its behalf (e.g. a

Classification Society such as ABS), will need to confirm compliance with the applicable regulations

contained within the Annex; the certificate's continuing validity will require annual, intermediate and

renewal surveys to be satisfactorily carried out and, being a statutory certificate, it will come under

the scrutiny of port State control inspectors wherever the ship plies her trade.

5.3

Whilst the majority of Annex VI will only apply to new and existing ships after entry into force of the

1997 Protocol there are two regulations which will be applied retrospectively from 01 January 2000,

namely Regulation 13 on NOx and Regulation 16 on shipboard incinerators, where a new ship will be

defined as one constructed on or after that date. For further details refer to section 2 of these

Guidance Notes.

7 Why Shipping

7.1Why the sudden interest in shipping which, after all, is considered by many to be the most

environmentally friendly method of transporting cargoes around the world; as has been stated earlier,

this is in no small way due to the pressures that have been placed upon industry ashore to

demonstrate compliance with increasingly more stringent emission standards.

7.3

Many countries have legislation in place to control or prevent air pollution, some of which is

internally driven but most being as a direct result of international Conventions and their associated

Protocols: for the protection of the ozone layer there is the Vienna Convention and its related

Montreal Protocol; the Framework Convention on Climatic Change (FCCC) is primarily concerned

with greenhouse gas emissions whilst some 40 States in and around the European landmass, togetherwith the USA and Canada, are signatory to the Convention on Long Range Transboundary Air

Pollution (LRTAP), This latter Convention has five related Protocols which have also been ratified

ABS' '' GUIDANCE NOTES ON PREVENTION OF AIR POLLUTION FROM SHIPS, MARCH 1999



Section 1 Introduction

by various parties to that Convention and have now entered into force, namely: the 1984 Protocol on

the Co-operative Programme for Monitoring and Evaluation of the Long Range Transmission of Air

Pollutants in Europe (EMEP); the 1985 Sulfur Protocol; the 1988 NO,, Protocol; the 1991 VOC

Protocol; and, the 1994 Sulfur Protocol. A further two Protocols to the Convention have been

approved and are presently open for signature by contracting Parties, these are the 1998 Heavy

Metals Protocol and the 1998 Persistent Organic Pollutants Protocol.

7.5

It is interesting to note that the LRTAP Convention and existing Protocols do not address shipping

although this may change with the development of the second step to the NO Protocol where a multi-

pollutant approach will be applied, addressing photochemical pollution, acidification and

eutrophieation a draft Protocol could be tabled by the end of 1999 and it is envisaged that it will

contain technical annexes on emissions from mobile sources, including shipping. In the mean time

the United Nations Convention on Law of the Sea (UNCLOS), which acts as an "umbrella" treaty for

international shipping, remains the sole guardian of the atmosphere but only up to 200 miles from a

coastal State's coastline.

6BS' GUIDANCE NOTES ON PREVENTION OF AIR POLLUTION FROM SHIPS, MARCH 1999



GUIDANCE NOTES ON


FROM SHIPS

SECTIONRetrospective Regulatory

Compliance (Early compliance

from 01 January 2000)

CONTENTS

1 Genera 9

3ew diesel engines and the NOx Technical Code05ncinerators1

ABS' GUIDANCE NOTES ON PREVENTION OF AIR POLLUTION FROM SHIPS, MARCH 1999



GUIDANCE NOTES ON


FROM SHIPS

SECTIONRetrospective Regulatory

Compliance

(Early compliance from 01 January

2000)

General

1.1Whilst Annex VI is not enforceable, internationally, until such time as it enters into force there are

two regulations which will be retrospectively applied in many areas of the world on the date of entry

into force of the Annex. These regulations concern NO emissions from "new" and "substantially

modified" diesel engines (Regulation 13) and "new" Shipboard Incinerators (Regulation 16), both of

which refer to a compliance date of 01 January 2000 regardless of the date of entry into force of

Annex VI. Actual compliance with the pertinent parts of these regulations after Ol. January 2000,

whilst not mandatory, is recommended for the following reasons:

It is far easier, and more cost effective, to order equipment to be supplied in accordance with

new specifications, than attempt to upgrade existing equipment to meet standards for which it

was not originally designed;

1.1.2

The time scale between the Annex meeting the entry into force requirements and its actual

date of entry into force is only 12 months, which may well be insufficient to arrange

compliance with those regulations and/or standards;

1.1.3

A flag State's introduction of domestic legislation, prior to entry into force, to enable it to

become a Party to the Protocol of 1997 by "signature without reservation, acceptance or

approval" may mean its own vessels being required to fully comply before entry into force of

the Annex; and,

ABS' GUIDANCE NOTE S ON PREVE NTION OF AIR POLLUTION FROM SHIPS, MARCH 1999



Section etrospective Regulatory Compliance

1.1.4

Non-compliance after entry into force of Annex VI may well result in a port State detention,

and/or prohibition from trading to and from that port or coastal State until such time as

compliance can be demonstrated.

1.3

Irrespective of the above, it is ultimately the Owner's responsibility to ensure that his vessel complies

with the national regulations of the State, the flag of which his ship is entitled to fly; this may well

include early compliance with Regulations 13 & 16, and may also require interim measures to be

taken to reduce emissions of other pollutants covered by the Annex. For those flag States who have

authorized ABS to act on their behalf instructions on the degree of compliance required will be

available through the local ABS Office. Early confirmation of a flag State's requirements, either

directly, or through ABS, is therefore strongly recommended.

3 New diesel engines and the NO Technical Code

3.1

The NO Technical Code was developed by a small group of experts within the IMO and is of a

highly technical nature, being based on the relevant parts of the International Standards Organization

publication ISO 8178 and providing a common basis for the NO testing of marine diesel engines. It

also includes information on certification procedures for different types of engines as well as onboard

verification procedures for demonstrating continuing compliance with the applicable NO emissions

limits. Due to the size of the NO Technical Code it has not been reproduced as an appendix to

these Guidance Notes.

3.3Regulation 13 of Annex VI basically requires that all diesel engines with individual power outputs

greater than 130 kW, which are installed on ships operating internationally and constructed on or

after 01 January 2000, comply with the applicable NO„ emission limits as set out in Regulation

13(3)(a) and chapter 3 of the NO Technical Code. Engines undergoing major conversion after 01

January 2000, as defined in Regulation 13(2)(a) and 1.3.2 of the NO Technical Code, are also

included but diesel engines for emergency use, and those installed on vessels solely engaged in

domestic trade are exempt providing they meet the requirements laid down in sub-paragraphs (b) &

(c) of Regulation 13(1). The Annex does not address NO„ emissions from ships boilers, gas turbines

or incinerators although this may change in the future. For further information on future emission

controls refer to section 5 of these Guidance Notes.

3.5

As has already been explained, until such time as the Annex enters into force its regulations are

unenforceable; this means that for Regulation 13, although an engine may have been certified as

being NO„ compliant at the time of its manufacture, evidence of continuing compliance may not be

required until such time as the initial survey for issuance of the International Air Pollution Prevention

Certificate (IAPPC) is carried out. The issuance of such a certificate to ships constructed before the

date of entry into force of the Annex, as per MARPOL VI/6(2), may be delayed by up to 3 years.

10BS'' GUIDANCE NOTES ON PREVENTION OF AIR POLLUTION FROM SHIPS, MARCH 1999




ACTIONn order to avoid the retrospective regulatory compliance problems associated with

NO emissions, prudent Owners should ensure that diesel engines installed on ships

constructed on or after 01 January 2000, and diesel engines which undergo a major

conversion on or after that date, are:

• "certified" in accordance with the NO Technical Code,'

• supplied with an "approved Technical File"; and,

• maintained in continuing compliance with the relevant NO emission limits

including "documentary evidence" of same.

Note 1: The term "certified", as used in the above context, is taken to mean that an engine has been

pre-certified and/or certified by an authorized Authority such as the vessel's flag Administration

or a Recognised Organizationl acting on its behalf in accordance with the requirements of 2.2 and

2.3 respectively of the NO, Technical Code. Prior to entry into force of Annex VI this "certification"

should take into consideration the contents of MEPC/Circ.344.

Note 2: The term "approved Technical File" is taken to mean a Technical File meeting the

requirements of 2.4.1 of the NO Technical Code and approved by an authorized Authority such as

the vessel's flag Administration or a Recognised Organization acting on its behalf,

Note 3: The term "documentary evidence" is taken to mean a properly completed Record Book of

Engine Parameters, or records of onboard emission testing either by the simplified measurement

method or by direct measurement and monitoring, all in accordance with the relevant sections of

chapter 6 of the NOx Technical Code.

3 .7

Further infotination on options for the control of NO emissions, as well as brief descriptions on the

certification of engines, the Technical File, the Record Book of Engine Parameters and onboard NO

measurement can be found in section 4.7.3 of these Guidance Notes.

5 Incinerators

5.1

Regulation 16 of Annex VI requires that all shipboard incinerators installed on ships on or after 01

January 2000 are approved by the Administration based on the requirements contained in IMO

Resolution MEPC 76(40) on Standard Specification for Shipboard Incinerators; such incinerators

must also be operated within the limits laid down in section A1.5 of Annex 1 of MEPC 76(40), which

is reproduced in section 4.7.9.1 of these Guidance Notes. Regulation 16(4) prohibits the incinerationof MARPOL Annex I, II & III cargo residues and related contaminated packing materials,

polychlorinated biphenyls (PCBs), garbage contaminated with heavy metals and refined petroleum

products containing halogen compounds. The incineration of sewage sludge and sludge oil,

generated during the normal operation of the ship, is allowed in main or auxiliary power plant or

boilers as per Regulation 16(5) but incineration by such methods is banned in ports, harbours and

estuaries.

ABS is a Recognised Organization and is authorized to issue statutory certification for most Administrations; the

local ABS Office will be able to advise whether ABS has been authorized by a specific flag Administration to

issue the relevant certification for Annex VI and the NQ Technical Code.





5.3

Incinerators installed on board ships prior to 01 January 2000, the vast majority of which have

already been approved in accordance with the earlier version of the Standard Specification for

Shipboard incinerators contained in IMO Resolution MEPC 59(33), may still be used after entry into

force of the Annex although the incineration of polyvinyl chlorides (PVCs) in them will be prohibited

by Regulation 16(6). Incinerators installed on vessels solely engaged in domestic trade may be

exempted from the 01 January 2000 deadline but only up to entry into force of the Annex.

5.5

As with the NO regulation, until such time as the Annex enters into force Regulation 16 is

unenforceable; this means that although an incinerator may have been type approved in accordance

with MEPC 76(40) at the time of its manufacture, evidence of its operation within the prescribed

limits and operator training may not be required until such time as the initial survey for issuance of

the IAPPC is carried out.

ACTIONn order to avoid the retrospective regulatory compliance problems associated with

incinerators, prudent Owners should ensure that incineration equipment "installed"

on board ship on or alter 01 January 2000 is:

•approved" in accordance with resolution MEPC 76(40);

•upplied with a manufacturer's operating manual;

•operated only by competent personnel; and,

• maintained in a condition which allows operation within the prescribed limits at

all times.

Note 1: The term "approved", as used in the above context, means type approved by an authorized

Authority such as the vessel's flag Administration or a Recognized Organization acting on itsbehalf.

Note 2: The term "installed", as used in the above context means that for existing ships the

incinerator is completely connected and ready for light-off. For new ships the term "installed" is

taken to mean installed on ships constructed on or after 01 January 2000.

Note 3: Incinerators with capacities greater than 1500 kW cannot, by definition, be type approved in

accordance with the current version of MEPC 76(40). However, experience has shown that where

such incinerators are installed on vessels, flag Administrations have been agreeable to a "Statement

of Compliance" with MEPC 76(40) being issued in lieu of the required IMO type approval

certification.

12BS' GUIDANCE NOTES ON PREVENTION OF AIR POLLUTION FROM SHIPS. MARCH 1999



ABS

GUIDANCE NOTES ON


FROM SHIPS

SECTION 3 Control of Other Pollutants

(Before & after entry into force of

Annex VI)

CONTENTS

1eneral53zone Depleting Substances65ulfur Oxides (SOX )67olatile Organic Compounds (VOC's)79uel Oil Quality9

ABS' GUIDANCE NOTES ON PREVENTION OF AIR POLLUTION FROM SH IPS, MARCH 19993



Section ontrol of Other Pollutants

3 Ozone Depleie. Substances

3.1

Regulation 12 of Annex VI, upon entry into force, will prohibit the deliberate emission of ozone

depleting substances such as halons and chlorofluorocarbons (CFCs) unless the safety of the ship and

its passengers and/or crew is likely to be jeopardized. for example where a halon system is discharged

for fire fighting purposes. Deliberate emissions do not include minimal releases of ozone depleting

substances associated with system commissioning, maintenance or decommissioning; however leaks,

whether deliberate or otherwise, may be regulated by flag or coastal States. The regulation also

requires that all of the substances covered by the regulation, as well as machinery and equipment

containing same, should be delivered to appropriate reception facilities upon removal from ships.

The provision for reception facilities is covered by Regulation 17 of Annex VI and is further

discussed in section 4.7.11 of these Guidance Notes.

33The cut-off dates referred to in Regulation 12 are based on those contained in the relevant sections of

the Montreal Protocol (as amended); the use of Halon in new fixed fire fighting installations has

already been banned under SOLAS as of 1st October 1994 (SOLAS 11-2/5.3.1), and [MO is

considering similar action for portable halon extinguishers. The use of CFCs (mainly utilized in air

conditioning and refrigeration units) will be prohibited in all new installations after entry into force

of Annex VI although many areas of the world have already banned their use in land based industrial

and non-industrial machinery, this in many cases includes marine applications as well. Hydro-

chlorofluorocarbons (HCFCs) will be permitted in new installations until 01 January 2020, but again

there are areas in the world, for example the European Union, where these gases may become

unavailable earlier due to a more severe regional phase-out schedule than that required by

international regulation.

CAUTIONhilst some equipment containing or utilizing CFCs will still he available fir use in

new installations prior to entry into force of Annex VI, prudent Owners should take

into consideration the likely availability of replacement gases in the areas of

operation of their vessels. Consideration should also he given to any impending

legislation from a vessel's flag State, or indeed coastal States, should a vessel he

employed on a dedicated service or route. As the production of ozone depleting

substances is reduced and eventually ceases, the only reliable source of

replenishment for existing plant is likely to be an ever dwindling stock of recycled

gases available from the .Halon and CFC International Banking Systems which have

been developed to conserve existing stocks of the gases for essential users.

5 Sulfur Oxides (SOX}

5.1

Regulation 14 on the control of emissions of SO, will, unlike the NO regulation, apply to all ships

upon entry into force of Annex VI and will also apply to every type of combustion equipment

regardless of its end use, whether that be propulsion, power generation. auxiliary machinery or for

emergency purposes. There will, however, be a period of grace to allow vessels time to comply with

this regulation where, for instance, structural alterations are required to account for changes in

onboard fuel oil tank arrangements and fuel oil distribution systems.

16 BS" GUIDANCE NOTES ON PREVENTION OF AIR POLLUTION FROM SHIPS, MARCH 1999




5.3

Regulation 14(1) mandates a global cap of 4.5% mini for the sulfur content of any oil fuel intended

for use on board ships; Regulation 14(4) places additional controls on designated Special Areas,

which are to be known as SO, Emission Control Areas (SO,ECAs), where the maximum sulfurcontent of any fuel oil used will be further limited to 1.5% rn/rn (or, where post combustion treatment

is utilized, the emission rate will be limited to a maximum of 6.0 g SO X /kWh). The sulfur content of

each parcel (bunker lifting) of oil fuel intended for use on board ship will also require to be

documented by means of a "Bunker Delivery Note" which must be kept on board for a period of 3

years after delivery of the fuel to which it relates. Information to be included in the bunker delivery

note required by Regulation 18(3) is included as appendix V to Annex VI and reproduced as

appendix 2 to these Guidance Notes.

5.5

SO, Emission Control Areas will be strictly controlled by Annex VI with criteria and procedures for

their designation contained as appendix III to that Annex. At the time of adoption of the new Annexin September 1997 the only area designated as a SO, Emission Control Area was the Baltic Sea;

however, the North Sea States are presently preparing a case for the designation of the North Sea

which, if successful, is likely to become effective upon entry into force of the new Annex. As has

already been stated, options for compliance with the emission limits of a SO X ECA are presently

limited to the use of low sulfur fuel, or utilization of an exhaust gas cleaning system as per

Regulation 14(4)(b) of the Annex. Where fuel switching is to be used for compliance with the lower

limits, change-over to the lower sulfur fuel will have to be carried out in such a manner as to ensure

that all the higher sulfur fuel is flushed out of the system prior to entry into the SO X ECA as per

Regulation 14(6). For further details refer to section 4.7.5 of these Guidance Notes.

5.7

There is also a requirement, at Regulation 14(2), to monitor the world-wide average sulfur content of

residual fuel oil which, whilst not directly affecting the shipowner, will initially be calculated based

on the results of fuel oil samples submitted, by owners, to the three major bunker fuel oil testing

companies, of which ABS Oil Testing Services is one.

CAUTIONhilst the regulation pertaining to SO, ECAs will not become effective until at least

12 months after entry into . force of the Annex prudent Owners, when considering

specifications Jr. future new buildings, may wish to take into account the likely areas

of operation of those new vessels with respect to existing or proposed SO„ Emission

Control Areas. For those vessels which will be trading in and out of ports within

SO, ECAs, on more than an occasional basis, an early review of fuel oil storage and

distribution systems to cater for high and low sulfiir fuels, or of alternative exhaust

gas cleaning systems, should be carried out. Methods of compliance with this

regulation are more 'idly discussed in section 4.7.5 of these Guidance Notes.

7 Volatile Organic Compounds (VOC's)

7.1

Regulation 15 deals with the control of emissions of Volatile Organic Compounds (VOC's) from oil

chemical and gas tankers only but, unlike other pollutants covered by the Annex, VOC's are not to

be universally controlled. In order for a port or terminal to be designated as a VOC control area it

will be necessary for the relevant coastal State Administration to declare that port or terminal as suchto the Organization (MO), provided of course that the Administration is signatory to the 1997

Protocol (Annex VI). Not all ports and terminals under the jurisdiction of an Administration may be

ABS' GUIDANCE NOTE S ON PREVE NTION OF AIR POLLUTION FROM SHIPS, MARCH 19997




affected by such a declaration and not all types and sizes of tankers visiting ports or terminals, which

are to be controlled, will necessarily be required to comply with the regulations as it will be up to the

Administration to designate cargo types and tanker size as well as ports and terminals to be

controlled.

Before an Administration can declare a port or terminal a VOC control area that port or terminal must

be provided with a vapor emission control system (VECS) which is in compliance with the safety

standards laid down in MSC/Circ.585 on Standards for Vapour Emission Control Systems. Tankers

using a port or terminal, which is subject to VOC emission controls during loading, must be fitted

with a means of collecting VOCs for return of same to the shoreside facilities and this system must

also be in compliance with the requirements of MSC/Cire.585, thus ensuring compatibility between

ship and shore.

7.3

7.5

A number of countries, including the USA, UK and Norway, already have ports or terminals undertheir jurisdiction fitted with vapor emission control systems, either on a voluntary basis or as a result

of legislation enacted under the 1991 VOC Protocol to the LRTAP Convention. What is not clear, at

present, is whether or not the operations of Floating Production, Storage and Off-loading facilities

(FPSOs) and Floating Storage Units (FSUs) are to be included under this regulation as, technically,

when operating within the jurisdiction of a coastal State, they could be classed as terminals. The

IMO is currently considering the role of drilling and production platforms, FPSOs and FSUs under a

general review of MARPOL and its applicability to the operations of such vessels; it should also be

noted that there are no internationally agreed safety standards presently available for controlling

VOC emissions from such vessels during loading (from a well) and discharging to shuttle tankers.

It is the Administration's responsibility to ensure that the IMO is advised as to which of its ports or

terminals will be subject to VOC controls, which cargoes will be controlled, the size of ships to be

controlled and the effective date of implementation of such controls. It is the Owner's

responsibility to ensure that his vessels are equipped in accordance with the requirements of

MSC/Circ.585 prior to entry into ports or terminals where VOC controls are being

implemented.

7.7

7.9

As has been stated above a number of countries have already installed, or are in the process of

installing, vapor emission control systems in some of their ports or terminals in order to combat local

problems associated with VOCs. In some ports their use is optional but in many it is mandatory with

some vessels being denied access to ports if they are not fitted with an approved VECS, this howeveris a rare occurrence as non-compliant vessels are usually sifted out at the chartering stage. The IMO,

in recognition of the fact that there has been an increase in the number of ports and terminals

declaring controls on VOC emissions prior to entry into force of the new Annex, adopted, at the

MEPC's 42' session, MEPC/Circ.345 on "Notification to the Organization on Ports or Terminals

where Volatile Organic Compounds (VOCs) Emissions are to be Regulated". The purpose of the

circular is to allow the IMO to collate and distribute, to its members, details of ports and terminals

regulating VOCs and conditions imposed on ships using those ports. A copy of the circular is

included as appendix 3 to these Guidance Notes.

18 BS} GUIDANCE NOTES ON PREVENTION OF AIR POLLUTION FROM SHIPS, MARCH 1999




7.11

In the United States it is now a requirement for every tank vessel, whether or not US flagged, wishing

to load flammable or combustible cargo in a port where vapor control is required, to be fitted with an

approved vapor collection system. The US Coast Guard will endorse the vessel's Certificate ofInspection (US flag) or Certificate of Compliance (non-US flag) after confirmation by the vessel's

Classification Society that it meets the requirements of Title 46 CFR part 39 (substantially similar to

the requirements of MEPC/Circ.345). Vessels not fitted with a VECS can obtain the relevant

endorsement to the COC but will only be able to load and perfoi

n ballasting and other operations at

ports or facilities where vapor control is not required. These requirements do not effect cargo

unloading provided the vessel is kept vapor tight until the vapors remaining in the cargo tanks after

unloading can be discharged to a facility ashore.

CAUTIONor new and existing vessels which are fitted with a standard inert gas system the

cost of modifying same to allow cargo vapor return to shoreside during loading is

minimal, all that is generally required is an additional manifold connection, to the

inert gas main, on each side of the ship with appropriate shut-off valves and safetydevices as specified in the referenced MSC circular. Prudent Owners may,

therefore, wish to consider early conversion of their existing tankers to ensure the

maximum trading possibilities around the world. However, Owners of smaller

tankers, which are less than 20,000 tons deadweight and therefore not bound by the

requirement for mandatory installation of an inert gas system, may wish to consider

the cost implications of retrofitting an entire vapor return system in order to comply

with future VOC controls in known sensitive areas (e.g. certain parts of Northern

Europe & the USA) as against including such a system in the specification for all

new buildings intended for use in those areas.

9uel Oil Quality

9.1

The operative sections of Regulation 18 after entry into force of the new Annex, as far as the

shipowner is concerned, are paragraphs (1) through (6); implementation of paragraphs (7) and (8) are

under the direct responsibility of individual Parties to the Protocol of 1997 and are intended to assist

in the control of fuel oil quality by regulating the bunker suppliers.

9.3

Regulations 18(1) and 18(2) define the term fuel oil, for the purposes of Annex VI, and indicate those

additives, substances and chemical wastes which are allowed or prohibited in fuel oil to be used for

combustion purposes on board ships. It should be noted that the wording of Regulation 18(1)(a) hasalso been adopted, in a recommendatory nature, by the International Standards Organization in their

1996 Specification for Marine Bunker Fuels, ISO 8217, and therefore all fuel oil ordered and

supplied to this ISO Specification should already be in compliance with MARPOL VI/18.

Regulations 18(3) through 18(5) lay down requirements for the issuance, receipt, maintenance on

board and inspection of documentation (bunker delivery notes) pertaining to the chemical and

physical properties of fuel oil for use on board ships and are applicable to every ship of 400 gross

tonnage or above and every fixed and floating drilling rig and other platfoiuis which have been or

will be issued with an International Air Pollution Prevention Certificate. Regulation 18(6) requires

that for each bunker delivery, a representative sample of the fuel oil delivered shall be taken and

maintained on board until the fuel is substantially consumed but in any case for a minimum period of

twelve months. Guidelines for the taking of representative bunker samples have yet to be developed

by the IMO but it is expected that they will substantially follow the ISO requirements for manual and

automatic sampling contained in ISO 3170 & 3171 respectively, as well as the recommendations

ABS'" GUIDANCE NOTES ON PREVEN TION OF AIR POLLUTION FROM SHIPS, MARCH 19999



GU IDANCE NOTES ON

PREVENTION OF MR POLLUTION

FROM SHIPS

SECTIONCompliance With Annex

(Including a review of some of the

options available)

CONTENTS

1 General 23

3hapter 1 - General35hapter ll - Survey, Certification and Means of Control47hapter Ill - Requirements for Control of Emissions from

Ships 25

7.3egulation 13 - Nitrogen Oxides67.3.1 General 26

7.3.2 Background 27

7.3.3 Requirements 27

7.3.4 NO, Reduction Options77.3.5ngine Pre-certification Requirements87.3.6 Clarification of Engine Family, Engine Group and

Parent Engine97.3.7 The Technical File07.3.8inal Certification17.5egulation 14 - Sulfur Oxides27.7egulation 15 - Volatile Organic Compounds57.9egulation 16 - Incinerators67,11egulation 17 - Reception Facilities77.13egulation 18 - Fuel Oil Quality8

7.15egulation 19 - Offshore Installations9ABS`` GUIDANCE NOTES ON PREVENTION OF AIR POLLUTION FROM SHIPS. MARCH 19991



GU IDANCE NOTES ON


FROM SHIPS

SECTIONCompliance With Annex

(Including a review of some of the

options available)

General

The overall content of the new Annex has already been reviewed in section 1 of these Guidance

Notes where it was explained that Annex VI chapters 1 & II closely follow the format of MARPOL

Annex I with regard to titles and content of the regulations. It has also been pointed out that, unlike

the previous three MARPOL Annexes which arc all optional, this Annex has been introduced bymeans of a Protocol so that, upon entry into force, all Convention ships of Parties to MARPOL 73/78

will require to be issued with an International Air Pollution Prevention Certificate. Section 2 of the

Guidance Notes dealt with those aspects of Annex VI and the NO Technical Code which require

action to be taken on or after 01 January 2000 whilst section 3 explained the requirements for

controlling the other pollutants mentioned in the Annex as well as options for compliance prior to its

entry into force. In this section a brief description of the regulations in chapters 1 & 11 of the new

Annex is given followed by a review of some of the options available for compliance with chapter III

of that Annex.

3 Chapter 1 - General

3.1Regulations 1 through 4 cover application, definitions, general exceptions and equivalents

respectively:

3.1.1

the air pollution Annex will apply to all ships; exemptions from compliance with individual

regulations within the Annex, by virtue of ship type, size or equipment application, are

indicated in the appropriate regulations;

3.1.2

definitions of terms used within the Annex are included in Regulation 2 but do not include

definitions of teins used in the NO Technical Code, the latter being found in chapter 1 of

that Code; for ease of reference a complete set of definitions are reproduced as appendix 4 to

these Guidance Notes;




SectionCompliance With Annex VI

3.1.3

exceptions, as in previous Annexes, are allowable where emissions necessary for the safety

of a ship or saving life at sea, or as a result of damage to a ship or its ec . u . : 1 : ; tv,:n t, renders

compliance impracticable; and,

3.1.4

equivalents allow the use of alternative fittings, material, appliance or apparatus provided

same are at least as effective as those required by the Annex and providing the Organization

is notified accordingly.

5hapter II Survey, Certification and Means of Control

5.1

Regulations 5 through 11 cover surveys and inspections, issue of an 1APP Certificate, issue of a

certificate by another Government, form of the certificate. duration and validity of the certificate, port

State control on operational requirements and detection of violations and enforcement respectively:

5.1.1

all ships of 400 gross tonnage and above, and all fixed and floating drilling rigs and other

platforms will be subject to initial, periodic and intermediate surveys as indicated in the

regulation, the wording being similar to previous Annexes. For ships of less than 400 gross

tonnage the degree of compliance with the Annex is left up to the individual Administrations.

There are also the standard requirements regarding use of Recognized Organizations,

implementation of unscheduled inspections, action to be taken when condition of equipment

does not substantially correspond with particulars of the certificate, maintenance of

equipment and Owners responsibilities for reporting accidents and/or defects to theappropriate Authorities;

5,1,2

IAPP Certificates will require to be issued to all ships of 400 gross tonnage or above engaged

in international voyages and to all platfois and drilling rigs engaged in voyages to waters

under the sovereignty or jurisdiction of other Parties to the 1997 Protocol. Vessels will be

expected to comply with this regulation no later than the first drydocking after entry into

force of the Annex but in any case no later than 3 years after entry into force;

5.1,3

certificates may be issued by another Government subject to the standard requirements(pertaining to survey, wording of the certificate and the vessel's flag State being a party to

the 1997 Protocol) being met;

5.1.4

the form of the certificate is included as an appendix to the Annex and is also required to be

completed in either English, French or Spanish if the language used is different to those

languages;

5.1.5

the maximum duration of an IAPP Certificate is limited to five years with the proviso that it

may be extended by up to 5 months to allow a vessel to return to its home port or to a port

where it is to be surveyed. The validity of the certificate is governed, as with other statutory

2 4 BS' GUIDANCE NOTES ON PR EVENTION OF AIR POLLUTION FROM SHIPS, MARCH 1999




certificates, by the star dad. requirements for inspections and surveys, confirmation that no

significant unauthorized alterations to equipment and fittings have occurred wick of course,

change of flag;

5.1.6the regulation on port State control on operational requirements is identical to those found in

the other• MARPOL Annexes;

5.1.7

additionally, a regulation on detection of violations and enforcement (Regulation 11) is

included in the Annex which does not appear in the other Annexes, although similar wording

can be found in Article 6 of the 1973 MARPOL Convention. The reason for inclusion of that

article in this regulation is to legally differentiate between emission (into the air) and

discharge (into the sea). The regulation also references the international law concerning the

prevention, reduction, and control of pollution of the marine environment, including the law

relating to enforcement and safeguards (United Nations Convention on the Law of the Sea

(UNCLOS)) which will apply mutatis tnutandis (with the necessary changes) to the rules and

standards set forth in Annex VI,

7 Chapter III - Requirements for Control of Emissions from

Ships

7,1 Regulation 12 - Ozone Depleting Substances

7.1.1

Upon entry into force of the Annex all new installations containing ozone depleting

substances will be prohibited, existing systems will continue to be acceptable but their life

expectancy will obviously depend on availability of replacement gases; those systems with

minimal leakage rates may continue to give service for many years but those where leakage is

excessive, or where the system is totally or partially discharged, for example for the purposes

of fire fighting, will need to be replaced or converted sooner rather than later. The use of

HC.FCs in new installations will be permitted until 01 January 2020.

CAUTIONhere it is decided to continue to use equipment containing or utilizing

CFCs after entry into force of Annex VI, prudent Owners will take steps to

ensure that the equipment is properly maintained and gas leakages reduced

to an absolute minimum whilst also taking into consideration the likely,

availability of replacement gases in the areas of operation of their vessels.

As the production of ozone depleting substances is reduced and eventually

ceases, the only reliable source of replenishment for existing plant is likelyto be an ever dwindling stock of recycled gases available from the Ha lon and

CFC International Banking Systems which have been developed to conserve

existing stocks of the gases fbr essential users.

WARNING As the global stocks of CFCs are further reduced the second hand market

for same will become more lucrative and there is no doubt that, in some

areas of the world, ports operating reception facilities for such gases, in

accordance with Regulation 17 of Annex VI, will offer recovered

refrigerants for direct re-use without any form of reprocessing (despite

what the accompanying certification may state). The use of such

refrigerants to make good loses through leakages may cause irreversible

contamination of an otherwise healthy system resulting in the necessity for

premature replacement or upgrading of equipment.

ABS'" GUIDANCE NOTES ON PREVENTION OF AIR POLLUTION FROM SHIPS, MARCH 19995



Section 4 Compliance With Annex VI

7.1,2

The halons and CFCs which are typically found on board ship are listed in Regulation 2(6),

halons being generally associated with fire fighting systems and CFCs with refrigeration, air

conditioning systems and the production of certain types of insulation.

7.1.3

Halons are already prohibited for use in new fixed installations by SOLAS II-2/5.3.1 whilst

IMO is presently working to extend that ban to portable halon extinguishers as well.

Alternatives to baton systems are well documented and readily available, the most common

probably being CO2 although high and low pressure water fog systems are gaining

popularity, especially in high speed craft where space and weight are at a premium.

Perfluorocarbons (PFCs), which are nearly as effective as halons, are being offered as

another alternative but their use is likely to be restricted to specialist vessels, such as

submersibles, due to cost and their extremely high global warming potential (GWP). This

high GWP prompted the adoption of Conference Resolution No. 7 at the MARPOL

Diplomatic Conference which is intended to restrict their application to essential users only.

7.1.4

CFCs, such as RI I, R12, RI13, R1 14 & R115, are to be found in ships refrigeration systems

{both cargo and stores refrigeration plants) as well as in independent refrigerated containers

and air conditioning systems; one of the most common HCFCs to be found on board ships is

R22. Alternative fluids for use in air conditioning and refrigeration systems are well

documented and readily available, with new products being marketed at regular intervals.

Hydrofluorocarbons (HFCs) such as R23 & R134a are available and suitable for retrofitting

into existing systems, these halocarbons contain no chlorine and therefore have a zero ozone

depleting potential (ODP) although they do have a GWP and may therefore be subject to

controls at some future date. Another alternative being used on some reefer ships isammonia.

CAUTIONhen considering retrofitting environmentally friendly refrigerants to

existing plant prudent Owners will wish to establish the types of lubricating

oil, rubber seals and metals that are used in their plants in order to ensure

that new fluids are chemically compatible with those materials. Also, where

it is necessary to use a refrigerant that is a blend of fluids rather than a pure

fluid, for instance where specific properties are required to be met, care

should be taken to ensure availability of that blend in the areas of operation

of the vessel, especially when that blend may only be produced by one or two

manufacturers.

7.3egulation 13 - Nitrogen Oxides

73.1 General

The requirements for early compliance with the applicable paragraphs of MARPOL VI/13

and the NO Technical Code have already been discussed in section 2 of these Guidance

Notes where it was pointed out that, upon entry into force of the Annex, engines to which

Regulation 13(1) of the Annex applies will require to be surveyed in order to confirm

continuing compliance with the emission limits set out in Regulation 13(3)(a) of the Annex

prior to issuance of the IAPP Certificate Existing engines (those not included under

Regulation 13) will not be subject to any such inspections. Qualifying engines will also

have to be kept in compliance with the regulations and this will require to be confirmed

during annual, intermediate and renewal surveys for continuing validity of the IAPP

Certificate.

26 BS' GUIDANCE NOTES O N PREVENTION OF AIR POLLUTION FROM SHIPS, MARCH 1999




7.3.4(h) Fuel/Water Emulsion — the addition of fresh water to the fuel, and its subsequent

emulsification prior to injection into the engine can give typical reductions of produced NO

of 10% for each 10% of water addition. Engine manufacturers have reported successful trials

with up to 50% water addition but there can be a fuel consumption penalty of up to 1%

increase for each 10% addition of water.

7.3.4(0 Water Injection — as an alternative to fuellwater emulsions fresh water can be

directly injected into the engine although this will necessitate additional equipment for the

water injection system and is therefore more costly to install. Reductions of produced NO

similar to that expected from emulsions can be expected with typical reported reductions of

20-50%.

Humid Air Motor (HAM) Technique — this method reduces the produced NO by the

addition of wet steam to the engine's combustion air. The method is insensitive to fuel oil

quality and engine load and NO reductions of the order of 50-80% have been recorded.

There is no reported fuel consumption penalty and minimal increases in running costs

although an initial investment in additional plant will be required.

7.3.4(0 Selective Catalytic Reduction (SCR) — the most efficient method for NO reduction is

still the SCR which will give reductions in produced NO of up to 80-95% when using urea.

This system generally requires the use of low (less than 2%) sulfur fuel and, in addition to

initial high capital investment in plant, has increased running costs due to urea consumption

and eventual replacement of both oxidizing and reducing catalyst material. Unlike the other

options this system is an after-treatment device and is totally independent of the combustion

process and therefore potentially suitable for retrofitting to any existing engine.

7.3.5 Engine Pre-certification Requirements

7.3.5(a) For new diesel engines that are required to be in compliance with Regulation 13 ofAnnex VI it will ultimately be the engine manufacturer's responsibility to ensure that the

Administration, or Recognised Organization acting on its behalf, is supplied with sufficient

information to be able to assess a particular engine's degree of compliance with the NO

Technical Code. For engines which undergo major conversions it will be for the owner to

ensure that the company undertaking that work will provide the necessary information and

Technical File in order to satisfy the relevant Annex VI requirements.or the

Administration, or Recognized Organization acting on its behalf, the certification process

will involve both technical department and field surveyors and, until such time as Annex VI

enters into force, a "Statement of Compliance" will be issued in lieu of the Engine

International Air pollution Prevention (EIAPP) Certificate in accordance with

MEPC/Circ.344 on "Interim Guidelines for the Application of the NO Technical Code" as

approved by the Marine Environment Protection Committee at its 42'°Session in November

1998, a copy of the MEPC Circular is included as appendix 5 to these Guidance Notes.

7.3.5(h) The technical department's involvement in the certification procedure will include

an initial approval of an engine Technical File for the parent engine of each engine family or

engine group and subsequent confirmation that any engine which is to be installed on a vessel

is a bona fide member of an approved engine family or engine group. The initial approval

will include, but may not be limited to:

i)review and acceptance of the range of engine models to be included in an engine

family or engine group and the choice of parent engine to represent that family or

group;

a review and acceptance of the proposed test bed test procedure;

2 8 BS' GUIDANCE NO TES ON PREVEN TION OF AIR POLLUTION FROM SHIPS, MARCH 1999



Section 4 Compliance With Annex VI

7.3.6(b) The engine larnily concept may be applied to any series produced engines which,

through their design are proven to have similar NO:, emission characteristics, are used as

produced and subsequently not subject to any modifications during installation on board.

Where adjustable features are provided (e.g. for balancing cylinder peak pressures and

individual cylinder exhaust gas temperatures) they are to be such that no setting, orcombination of settings, can adversely affect the engine's NO„ emissions. For engines within

a particular family the applicable characteristics in chapter 4.3.8 of the Code should be

common to those engines.

7.3.6(c) The engine group concept may be applied to a smaller series of engines produced for

similar engine application and which require minor adjustments and modifications during

installation or in service on board. These engines are noialty large power engines for main

propulsion and, for engines within a particular group, the applicable characteristics in chapter

4.3.8 of the Code as well as those parameters and specifications indicated in chapter 4.4.5.2

of the Code should be common to those engines unless specifically indicated otherwise.

With regard to the allowable adjustments within an engine group the manufacturer is to

provide documentary evidence and/or historical data (e.g. previous test reports) tosubstantiate that the range of adjustments which are included in the Technical File will

permit the engine to operate within the emissions limits set down in MARPOL VI/13(3)(a)

and chapter 3 of the NO, Technical Code. It will be up to the attending surveyor at the time

of the parent engine test bed testing to confirm that the allowable adjustments (or

combinations of allowable adjustments where more than one parameter is documented as

being adjustable) do not result in the total weighted average of NO emissions of that engine

exceeding the permissible limits.

7.3.6(d) The parent engine of an engine family or group must be the engine which has the

worst (i.e. highest) NO emission characteristics of that engine family or group, as

documented by the manufacturer and approved by the Administration. For the engine family

concept the parent engine must be selected based on criteria contained in chapter 4.3.9.2 of

the Code. For the engine group concept the parent engine must be tested with the allowable

adjustments set to those positions documented in the Technical File which will give the worst

NO emission limits. The engine's actual NO emission value, as documented at section 1.15

of the supplement to the EIAPP Certificate (appendix 1 of the Code) is the value obtained at

the time of the test bed testing of the parent engine with the engine adjusted, within the

allowable parameters as documented in the Technical File, to give the worst case for

NOx emissions. This, in practice, will ensure that the parent engine and all members of the

family or group always operate at or below this worst case scenario and therefore are always

in compliance with MARPOL V1J13(3)(a) and chapter 3 of the NO Technical Code.

7.3.7 The Technical File

7.3.7(a) This document is required to be approved by the Administration or Recognised

Organization acting on its behalf, and shall as a minimum contain the undernoted

information:

identification of those components, settings and operating values of the engine which

influence its NO emissions;

ii) identification of the full range of allowable adjustments or alternatives for the

components of the engine;

iii) full record of the relevant engine's performance, including the engine's rated speed

and rated power;

30 BS'" GUIDANCE NOTES ON PREVENTION OF AIR POLLUTION FROM SHIPS : MARCH 1999



Section ompliance With Annex VI

en ships which require to trade within a SO.,,ECA will have L. mee.t the more

emission requirements laid down in Regulation 14(4) and the lengm of time thatna l -

ship spends in such an area is likely to dictate the means adopted by Owners for com? li

7.5.3(0) Primag Control. The use of a low sulfur (less than 1.5% m/m) fuel, as per

Regulation 14(4)(a) will limit the formation of the pollutant to, or below, the maximum

permitted i.e. 6.0 g SO,/kWh: compliance with the regulation can be demonstrated by

appropriate entries in the ship's official log book stating when and where the ship changed

over to using low sulfur fuel and the bunker tank ullages at that time. It will be necessary to

effect the change-over to the lower sulfur fuel in sufficient time to ensure that the ship's fuel

oil system is totally flushed of all fuels containing more than l.5% m/m sulfur content prior

to entry into a SO,ECA. Whilst low sulfur fuel oil may be readily available in certain parts

of the world, for example in Northern Europe where there is a requirement for large

quantities of sulfur controlled oil fuels from Utilities and other shore based users, and Where

a proportion of the crude oil feed stock to refineries tends to be low in sulfur anyway, it is

likely that many ships will opt to burn gas oil which is traditionally supplied with a maximum

sulfur content of 0.5% m/m and, in many cases, less than 0.2% m/rri.

7.5.3(h) Secondary Control. This will effectively be some form of exhaust gas cleaning

system, or other technological method which is "verifiable and enforceable", and will require

to be approved by the Administration based on guidelines to be developed by the

Organization. There are at present no approved guidelines for exhaust gas cleaning systems

although the Design and Equipment Sub-Committee have been given a target date for

completion of such guidelines by 2003 only if there is a demonstrable need for same. Present

day technology as applied to the design of scrubbers for use in inert gas installations is likely

to be the way forward in the medium term although such a scrubber plant may be

prohibitively large if required to handle the full exhaust gas flow from say a 20 MW slow

speed diesel engine which can amount to some 140 tonnes/hr. The possibility of part flow

systems are further discussed in section 5.5.4 of these Guidance Notes. The other main

problem with a scrubber unit is that it discharges a "waste stream", which has the potential of

being regulated under Regulation 14(4)(b), and that waste stream is also likely to be acidic in

nature requiring additional measures to be taken to avoid corrosion to the pipework and hull

penetration of the overboard discharge.

7.5.3

7.5.4

As has already been stated, a ship's trading patterns and, to a certain extent, engine type will

determine the options for complying with the emission limits in SO,ECAs once the Annex

has entered into force. Those ships powered by gas turbines, and those with diesel engines

which are permanently operated on gas oil will not be affected because of the low sulfur

content of the type of fuels used. Those ships permanently operating in SO,ECAs will

likewise be unaffected because the only fuel available for them to purchase will already have

a low (less than 1.5% rn/m) sulfur content whilst those ships which never enter a SO,ECA

will not be subject to the stricter emission limits and will also be unaffected. The ships

which may encounter problems are those which trade in and out of the emission control areas

and which predominantly operate on "standard" (i.e. greater than 1.5% mlin sulfur content)

marine bunkers for it is these ships which will require to switch fuels or engage an exhaust

gas cleaning system prior to entry into the SO,ECA.

ABS' GUIDANCE NOTE S ON PREVEN TION OF AR POLLUTION FROM SHIPS, MARCH 19993




7.5.7

Because of the variety of options available for addressing aspects relative to fuel switi.,twill be necessary to assess the cost implications associated with each before deciding on the

most appropriate method of compliance for individual vessels. The feasibility of carrying outmodifications to older ships will also depend on when the new regulations are likely to enter

into force. In order to carry out an adequate assessment, information on the availability of

low sulfur fuels in various parts of the world, including relative costs, will need to be made

available; the cost of carrying out structural modifications to existing fuel oil tank

arrangements and duplication of at least some of the distribution piping and equipment will

have to be investigated; and, the effects of loss of primary bunker space on a vessels

operational range, because of partitioning and/or isolation of existing tanks for use with low

sulfur fuel, will need to be considered.

CAUTIONn order to avoid some of the problems associated with fuel oil switching,

prudent Owners may wish to avail themselves of the services of a fuel oil

testing company, such as ABS Oil Testing Services, who will he able toconfirm the compatibility of oil fuels which will need to he mixed as well as

the sulfur content of low sulfur fuels taken on board to ensure that they are

in accordance with the information contained in the bunker delivery note

required by MARPOL VI/18(3).

With regard to lubricating oil, prudent Owners will also wish to ensure that

ships staff are aware of the potential problems of operating an engine lbr

prolonged periods using a fuel oil which has a sulfur content significantly

lower or higher than that which has been in use. Increased frequency of

testing may he recommended by the Owner to monitor the condition of the oil

thus avoiding possible costly repairs resulting from damage caused by

increased contamination of the oil by fuel and the products of combustion.

WARNING Until such time as the Annex enters into force it is not known how policing

of SO Emission Control Areas will be carried out although coastal States

bordering a SOxECA are likely to be more vigilant than those remote from

it. Whilst the first line of control will, in the majority of cases, be

examination of the bunker delivery notes and log book entries for fuel

switching, or examination of exhaust gas cleaning system operational

records when such equipment finally becomes available, any doubts on the

part of the PSC Inspector as to the accuracy of such records could trigger

a more detailed on-board investigation. Such an investigation may include

verification of the sulfur content offuel oil, both as delivered and as used,

and may lead to delays in a ship's departure while laboratory samples areanalyzed. Owners should also be aware that equipment for remote sensing

of exhaust gas plumes is available and already in use in some

Scandinavian Ports; such equipment is capable of being operated day or

night and readings in the region of 400 ppm SO2 concentration would

indicate use of a higher sulfur content fuel and also likely to trigger the

more detailed on-board inspection noted above.

7.7 Regulation 15 - Volatile Organic Compounds

7.7.1

As has already been explained in section 3.7 of these Guidance Notes, the control of VOCs is

only applicable to gas, chemical and oil tankers operating in ports or terminals under thejurisdiction of Parties to the 1997 Protocol who have signified their intention, to the IMO, to

implement such controls. It has also been explained that the operation of FPSOs and FSUs,

ABS' GUIDANCE NOTES ON PREVEN TION OF AIR POLLUTION FROM SHIPS MARCH 19995



Section ompliance With Annex VI

(b) CO in flue gas maximum mieragi.::00 mg/MJ

7.9. ( c) Soot number maximum average:ACFIARACH 3 or

R1NGELMAN 1

i.e. 20% opacity. (A higher soot number isacceptable only during very short periods such

as starting up)

7.9.1(d) Unburned components in ash residues:

ax 10% by weight

7.9.10 Combustion chamber flue gas outlet temperature range: 850-1200°C

Note 1: Flue gas outlet temperature and 0, content should be measured during the

combustion period, and not during the preheating or cooling periods.

Note 2: A high temperature in the actual combustion chamber/zone is an absolute

requirement in order to obtain a complete and smoke free incineration, including that of

plastic and other synthetic materials while minimising dioxins, VOCs and other emissions.

7.9.2

Operators of such incinerators will also have to be trained in their use taking into

consideration the contents of the mandatory operations manual required by Regulation 16(7)

to ensure that the incinerators are maintained and operated within the specified limits.

7.9.3

Existing incinerators installed on board ships prior to 01 January 2000 may still be used after

entry into force of the Annex although the incineration of polyvinyl chlorides (PVCs) in them

will be prohibited by Regulation 16(6).

7.9.4

As with the NO regulation, until such time as the Annex enters into force Regulation 16 is

unenforceable; this means that although an incinerator may have been type approved in

accordance with MEPC 76(40) at the time of its manufacture, evidence of its operation

within the prescribed limits and operator training may not be required until such time as the

initial survey for issuance of the IAPPC is carried out.

CAUTIONn order to avoid possible problems and/or delays with the issuance of the

JAPPC, prudent Owners should ensure that incineration equipment installed

on board ship on or after 01 January 2000 is maintained in a condition

which allows operation within the prescribed limits at all times: operators

should therefire be suitably trained and a copy of the manufacturer's

operating manual made available on board, all prior to entry into farce of

the new Annex. One method of ensuring the foregoing is to incorporate

incinerator operational requirements into the vessel's SKIS/ISM

documentation.

7.11 Regulation 17 - Reception Facilities

7.1 1 .1

This regulation has little impact on the Owner or Operator of ships in as much as the onus for

providing suitable reception facilities for ozone depleting substances, equipment containing

such substances and residues (waste streams) from exhaust gas cleaning systems (where these

are not permitted to be discharged under Regulation 14(4)(b)) lies with the Government ofeach Party to the Protocol of 1997 (i.e. signatories to MARPOL Annex. VI); the availability

of such facilities should not cause undue delay to ships.

ABS' GUIDANCE NOTES O N PREVENTION OF AIR POLLUTION FROM SHIPS, MARCH 19997



Section he Future

Manufacturers' quoted system specifications vary depending on the type of analyser utilised

and the medium being measured, but will include operational temperature ranges as well as

figures for accuracy and linearity, cross sensitivity, zero and span drift, repeatability and

response time. Many of the monitoring systems now available are PC based and have the

capability of displaying measurements in parts per million (ppm), ing/m3 , mg/kWh or simply

as a percentage. Some of the latest optical radiation systems incorporate on-line calibration

verification using sealed certified gas cells and filters enabling both zero and span checks to

be made automatically, thus removing the need to carry a range of calibration gases.

5.5.2(b) As to the use to which the various types of monitoring systems may be put there is

no need to look further than the normal day-to-day activities of such industries as power

generation, waste incineration, mineral wool production, cement manufacturing, chemical

manufacturing and refinement, fertilizer production, national air quality measurements and

aircraft emissions measurements in airports. Of relative interest to the marine industry is the

use of monitors in the power generation and waste incineration industries. In the power

industry, where selective catalytic reduction (SCR) is employed, emissions are typically

monitored for nitric oxide (NO), nitrogen dioxide (NO2 ) and ammonia (NH3 ); sulfur dioxide

(SO2 ) and water vapor may also be measured before and after scrubbers and processes

controlling lime dosage. In waste incineration plants, as well as monitoring the emissions

and processes noted earlier, hydrogen chloride (HCt), mercury (Hg), hydrogen fluoride (HF)

and carbon dioxide (CO2 ) may also be required to be monitored for emission control

purposes.

5.5.3 Types of Systems

5.5.3(a) Exhaust gas monitoring systems may be classified under two main headings, namely

extractive and in-situ. In extractive monitoring systems the gas is analyzed at a point remote

from the source, often after conditioning of the sample has taken place by one, or a

combination of processes such as filtering, drying, heating or cooling; this type of system

allows for analysis by electrochemical cell, chemiluminescence, paramagnetics or optical

radiation. In in-situ monitoring systems the measurement takes place in the stack with no

conditioning of the exhaust gas and is only suitable for analysis by optical radiation.

5.5.3(b) The choice of analyser will be dependent upon the gas or gases to be measured, the

measuring environment, the system classification (extractive versus in-situ) and the type of

monitoring to be carried out (continuous, semi-continuous, intermittent or spot check):

electrochemical cells rely on the change in electrical resistance of a gas sensitive

chemical when a particular gas passes over it and are suitable for use with most

gases; this methodology is popular with manufacturers of both portable and fixed gas

detectors, but is adversely affected by cross sensitivity and moisture, it also has alimited life (maximum two years) due to the gradual poisoning of the cell by the

gases to which it is exposed, although cell replacement is generally straightforward;

chetniluminescent analyzers, whilst limited to the measurement of NO x and

ammonia (NH3 ), are presently the most reliable and accurate method of measurement

for NOx and are the preferred method for measurement of this gas in a number of

countries; indeed, they are specified in the International Standards Organization

(ISO) standard ISO 8178, Part 1 on which the NO Technical Code is based.

Analysis is achieved by measuring the light emitted when nitric oxide (NO) is

converted to nitrogen dioxide (NO2 ) in the presence of ozone (03) whilst ammonia

content is calculated after first converting it to nitric oxide in a high temperatureoven;

ABS GUIDANCE NOTES O N PREVENTION OF AIR POLLUTION FROM SHIPS, MARCH 19997



GUIDANCE NOTES ON


FROM SHIPS

SECTION 6 Conclusions

ABS" GUIDANCE NOTES O N PREVENTION OF AIR POLLUTION FROM SHIPS, MARCH 19991



GUIDANCE NOTES ON


FROM SHIPS

SECTION 6 Conclusions

I

Regardless of presently available technologies (or lack of them) for the reduction and prevention of

ship generated air pollution the international shipping community has been left in no doubt as to the

growing concerns of environmentally conscious countries, and relevant international organizations,

with respect to what is now considered to be an unacceptably high percentage contribution to global

air pollution from shipping. As international emission reduction strategies result in increasingly

stringent discharge limits being applied to land-based industries, so the shipping industry will feel the

knock-on effects of such legislation and be subjected to ever greater scrutiny and further tightening of

the air pollution controls already adopted by MARPOL Annex VI..

3

As has been the case with other Annexes to MARPOL, the length of time between adoption of Annex

VI and its entry into force is likely to be determined by international pressures resulting from public

concerns on the effects of air pollution in various parts of the world. It has already been pointed out

that, unlike other forms of marine pollution, air pollution is transboundary in nature and can therefore

affect land-locked countries as well as those with coastlines.here can be few, if any,

environmentally aware people in the civilized world who have not heard of global warming, the

ozone layer, acid rain and smog; indeed, hardly a week passes without the publication of further

evidence of the effects of man's continuing pollution of the atmosphere that surrounds planet earth.

Most people are aware of the hole in the ozone layer and the rapid increase in the incidents of skincancer which have been attributed to this; acid rain not only kills forests and poisons water courses, it

also destroys the fabric of buildings; air quality in many urban areas is now so poor that not only is it

measured but the results are broadcast to alert vulnerable members of the public, primarily those with

respiratory problems; and of course, who is not familiar with the predictions regarding climatic

change that may occur as a result of global warming, the associated rises in sea levels as the polar ice

caps melt and the probable flooding of low lying coastal areas throughout the world.

There is nothing that the international shipping community can do to reverse the continuing quest for

a cleaner global environment; indeed, to ignore the concerns and requests for co-operation from

international organizations, such as the UNFCCC, may result in decisions taken by the IMO's MarineEnvironmental Protection Committee being effectively over-ruled by other United Nations bodies

who have relevant expertise in matters concerning protection of the environment.

ABS GUIDANCE NOTES O N PREVENTION OF AIR POLLUTION FROM SHIPS, MARCH 19993



Section 6 Conclusions

7

On the positive side, improvements in the design and operation of marine diesel engines have seen a

relative drop of some 30% in the levels of CO2 discharged to the atmosphere per ton of cargo moved;

regional agreements and/or requirements in some of the more sensitive parts of the world are already

giving local improvements to air quality; and, concerns regarding shipping's contribution to global

atmospheric pollution have resulted in concerted attempts to categorize and document the amounts of

the various pollutants attributed to international transport.

9

On the negative side, the improvements in CO, emissions from diesel engines noted above have

generally resulted in increased NOx emissions; proposed and pending legislation, such as the

requirements for NO reductions, ballast water exchange (for the minimization of transfer of harmfulaquatic organisms and pathogens) and the banning of anti-fouling paints containing TBTs are all

likely to increase CO2 and other exhaust gas emissions due to an increase in a vessel's fuel oil

consumption; and, regional agreements and requirements for pollution reduction strategies can result

in trade distortion, the transfer of cargoes to other less environmentally friendly modes of transport

and possible increases in air pollution for surrounding areas due to a shift in vessel trading patterns.

11

As can be seen from some of the above examples there are certain types of pollution presently under

consideration where the preferred reduction strategy will result in an increase in emissions to the

atmosphere of one or more of the pollutants to be controlled by the new Annex VI to MARPOL, The

interrelationship between these various different types of pollution, and their means of control, will

need to be carefully considered on the basis of a cost benefit analysis to ensure that a balance is

struck between benefits to the environment and cost to the industry. It is therefore extremely

important that the International shipping community continues to promote the environmentally

friendly aspects of the transportation of cargo by sea compared to other modes of transport and,

where possible, to demonstrate a commitment to reducing global atmospheric pollution by equipping

and operating ships, as far as is reasonably practicable, in accordance with the requirements of the

new Annex VI to MARPOL.

13

In order to assist owners and operators of ships, offshore platforms, drilling units and other marine

structures, as well as surveyors, builders, designers and manufacturers of marine equipment, in

assessing and accessing forthcoming legislation from flag Administrations and environmental

agencies, these Guidance Notes contain, at appendix 7, a list of useful web site addresses that were

available as of the end of March 1999.

54 BS GUIDANCE NOTES ON PREVENTION OF AIR POLLUTION FROM SHIPS, MARCH 1999



Appendix 'Ihapter III of MARPOL Annex VI

REGULATION 14

Sulphur Oxides (SOX }

General requirements(1)

he sulphur content of any fuel oil used on board ships shall not exceed 4.5% m/m.

(2)

he worldwide average sulphur content of residual fuel oil supplied for use on board ships

shall be monitored taking into account guidelines to be developed by the Organization.

Requirements within SOX Emission Control Areas

(3)or the purpose of this regulation, SO, Emission Control Areas shall include:

(a) the Baltic Sea area as defined in regulation 10(1)(b) of Annex 1; and

(b) any other sea area, including port areas, designated by the Organization in

accordance with criteria and procedures for designation of SO, Emission Control

Areas with respect to the prevention of air pollution from ships contained in

appendix 111 to this Annex.

(4)

hile ships are within SO, Emission Control Areas, at least one of the following conditions

shall be fulfilled:

(a) the sulphur content of fuel oil used on board ships in a SO„ Emission Control Area

does not exceed 1.5% mina;

(b) an exhaust gas cleaning system, approved by the Administration taking into account

guidelines to be developed by the Organization, is applied to reduce the total

emission of sulphur oxides from ships, including both auxiliary and main propulsion

engines, to 6.0 g SO,/kWh or less calculated as the total weight of sulphur dioxideemission. Waste streams from the use of such equipment shall not be discharged into

enclosed ports, harbours and estuaries unless it can be thoroughly documented by the

ship that such waste streams have no adverse impact on the ecosystems of such

enclosed ports, harbours and estuaries, based upon criteria communicated by the

authorities of the port State to the Organization. The Organization shall circulate the

criteria to all Parties to the Convention; or

(c) any other technological method that is verifiable and enforceable to limit SO,

emissions to a level equivalent to that described in sub-paragraph (b) is applied.

These methods shall be approved by the Administration taking into account

guidelines to be developed by the Organization.

(5)

he sulphur content of fuel oil referred to in paragraph (1) and sub-paragraph (4)(a) of this

regulation shall be documented by the supplier as required by regulation 18 of this Annex.

(6)

hose ships using separate fuel oils to comply with paragraph (4)(a) of this regulation shall

allow sufficient time for the fuel oil service system to be fully flushed of all fuels exceeding

1.5% m/m sulphur content prior to entry into a SO, Emission Control. Area. The volume of

low sulphur fuel oils (less than or equal to 1.5% sulphur content) in each tank as well as the

date, time, and position of the ship when any fuel-changeover operation is completed, shall

be recorded in such log-book as prescribed by the Administration.

(7)

uring the first twelve months immediately following entry into force of the present

Protocol, or of an amendment to the present Protocol designating a specific SO), Emission

Control Area under paragraph (3)(b) of this regulation, ships entering a SO, Emission

Control Area referred to in sub-paragraph (3)(a) of this regulation or designated under

AS UIDANCE NOTES ON PREVENTION OF AIR POLLUTION FROM SHIPS, MARCH 19999



Appendix Chapter III of MARPOL Annex VI

a ship before the date of entry into force of the Protocol of 1997, provided

that the ship is solely engaged in voyages within waters subject to the

sovereignty or jurisdiction of the State the flag of which the ship is entitled

to fly.

(3)

othing in this regulation affects the prohibition in, or other requirements of, the Convention

on the Prevention of Marine Pollution by Dumping of Wastes and Other Matter, 1972, as

amended, and the 1996 Protocol thereto.

(4)

hipboard incineration of the following substances shall be prohibited:

(a) Annex I, H and III cargo residues of this convention and related contaminated

packing materials;

(b) polychlorinated biphenyls (PCBs);

(c) garbage;as defined in Annex V of the present Convention, containing more than

traces of heavy metals; and

(d) refined petroleum products containing halogen compounds.

(5)

hipboard incineration of sewage sludge and sludge oil generated during the nonnal

operation of a ship may also take place in the main or auxiliary power plant or boilers, but in

those cases, shall not take place inside ports, harbours and estuaries.

(6)hipboard incineration of polyvinyl chlorides (PVCs) shall be prohibited, except in shipboard

incinerators for which IMO Type Approval Certificates have been issued.

(7)ll ships with incinerators subject to this regulation shall possess a manufacturer's operating

manual which shall specify how to operate the incinerator within the limits described in

paragraph 2 of appendix IV to this Annex.

(8)

ersonnel responsible for operation of any incinerator shall be trained and capable of

implementing the guidance provided in the manufacturer's operating manual.

(9)

onitoring of combustion flue gas outlet temperature shall be required at all times and waste

shall not be fed into a continuous-feed shipboard incinerator when the temperature is below

the minimum allowed temperature of 850°C. For batch-loaded shipboard incinerators, the

unit shall be designed so that the temperature in the combustion chamber shall reach 600°C

within 5 minutes after start-up.

(10)othing in this regulation precludes the development, installation and operation of alternative

design shipboard thermal waste treatment devices that meet or exceed the requirements of

this regulation.

REGULATION 17Reception Facilities

(1)

he Government of each Party to the Protocol of 1997 undertakes to ensure the provision of

facilities adequate to meet the:

(a) needs of ships using its repair ports for the reception of ozone depleting substances

and equipment containing such substances when removed from ships;

(b) needs of ships using its ports, terminals or repair ports for the reception of exhaust

gas cleaning residues from an approved exhaust gas cleaning system when discharge

into the marine environment of these residues is not petinitted under regulation 14 of

this Annex;

ABS' GUIDANCE NOTES O N PREVENTION OF AIR POLLUTION FROM SHIPS, MARCH 19991



Appendix 1 Chapter III of MARPOL Annex VI

without causing undue delay to ships, and

(c)eeds in ship breaking facilities for the reception of ozone depleting substances and

equipment containing such substances when removed from ships.

(2)

ach Party to the Protocol of 1997 shall notify the Organization for transmission to the

Members of the Organization of all cases where the facilities provided under this regulation

are unavailable or alleged to be inadequate.

REGULATION 18

Fuel Oil Quality

(1)uel oil for combustion purposes delivered to and used on board ships to which this Annex

applies shall meet the following requirements:

(a)xcept as provided in sub-paragraph (b):

i) the fuel oil shall be blends of hydrocarbons derived from petroleum refining.

This shall not preclude the incorporation of small amounts of additives

intended to improve some aspects of performance;

ii) the fuel oil shall be free from inorganic acid;

iii) the fuel oil shall not include any added substance or chemical waste which

either:

(I)eopardizes the safety of ships or adversely affects the performance

of the machinery, or

(2) is harmful to personnel, or

(3) contributes overall to additional air pollution; and

(b)

uel oil for combustion purposes derived by methods other than petroleum refining

shall not:

i)xceed the sulphur content set forth in regulation 14 of this Annex;

ii) cause an engine to exceed the NO emission limits set forth in regulation

13(3)(a) of this Annex;

iii)ontain inorganic acid; and

iv) (1)eopardizes the safety of ships or adversely affects the performance

of the machinery, or

(2) is harmful to personnel, or

(3) contributes overall to additional air pollution.

(2)

his regulation does not apply to coal in its solid form or nuclear fuels.

(3)or each ship subject to regulations 5 and 6 of this Annex, details of fuel oil for combustion

purposes delivered to and used on board shall be recorded by means of a bunker delivery note

which shall contain at least the infoiniation specified in appendix V to this Annex.

(4)he bunker delivery note shall be kept on board the ship in such a place as to be readily

available for inspection at all reasonable times. It shall be retained for a period of three years

after the fuel oil has been delivered on board.

(5)a)he competent authority of the Government of a Party to the Protocol of 1997 may

Refer to resolution A787(19), Procedures for port State control.

62BS GUIDANCE NOTES ON PREVENTION OF AIR POLLUTION FROM SHIPS, MARCH 1999



GUIDANCE NOTES ON


FROM SHIPS

APPENDIX

2 Information to be Included in theBunker Delivery Note (Regulation

18(3))

Name and IMO number of receiving 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)*

Fuel oil should be tested in accordance with ISO 3675

Fuel oil should be tested in accordance with ISO 8754

ABS ' GUIDANCE NOTES ON PREVENTION O F AIR POLLUTION FROM SHIPS. MARCH 19995



GUIDANCE NOTES ON


FROM SHIPS

APPENDIX 4 Definitions

For the purpose of MARPOL Annex VI:

A similar stage of construction means the stage at which:

(a) construction identifiable with a specific ship begins; and

(b) assembly of that ship has commenced comprising at least 50 tonnes or one per cent

of the estimated mass of all structural material, whichever is less.

Continuous feeding is defined as the process whereby waste is fed into a combustion chamber

without human assistance while the incinerator is in normal operating conditions with the combustion

chamber operative temperature between 850°C and 1200°C.

Emission means any release of substances, subject to control by Annex VI from ships into the

atmosphere or sea

New installations, in relation to regulation 12 of Annex VI, means the installation of systems,

equipment. including new portable fire extinguishing units, insulation, or other material on a ship

after the date on which the Annex enters into force, but excludes repair or recharge of previously

installed systems, equipment, insulation, or other material, or recharge of portable fire extinguishing

units.

NO Technical Code means the Technical Code on Control of Emission of Nitrogen Oxides from

Marine Diesel Engines adopted by Conference resolution 2, as may be amended by the Organization,

provided that such amendments are adopted and brought into force in accordance with the provisions

of article 16 of the present Convention concerning amendment procedures applicable to an appendixto an Annex.

Ozone depleting substances means controlled substances defined in paragraph 4 of article 1 of the

Montreal Protocol on Substances that Deplete the Ozone Layer, 1987, listed in Annexes A, B, C or E

to the said Protocol in force at the time of application or interpretation of this Annex.

Ozone depleting substances that may be found on board ship include, but are not limited to:

Halon 1211romochlorodifluoromethane

Halon 1301romotrifluoromethane

Halon 2402,2-Dibromo-1,1,2,2-tetrafluoroethane (also known as Baton 114B2)

CFC-11Triehlorofluoromethane

CFC- 12 ichlorodifluoromethane

ABS GUIDANCE NOTES ON PREVENTION OF AIR POLLUTION FROM SHIPS, MARCH 19999



Appendix 4 Definitions

Operating values are engine data, like cylinder peak pressure, exhaust gas temperature, etc., from the

engine log which are related to the NO emission performance. These data are load-dependent.

The E1APP Certificate is the Engine International Air Pollution Prevention Certificate which relates

to NO„ emissions.

The LAPP Certificate is the International Air Pollution Prevention Certificate.

Administration has the same meaning as Article 2, sub-paragraph (5) of MARPOL 73/78.

On-board NO verification procedures mean a procedure, which may include an equipment

requirement to be used on board at initial certification survey or at the periodical and intermediate

surveys, as required, to verify compliance with any of the requirements of this Code, as specified by

the engine manufacturer and approved by the Administration.

Marine diesel engine means any reciprocating internal combustion engine operation on liquid or dual

fuel, to which regulations 5, 6 and 13 of Annex VI apply, including booster/compound systems if

applied.

Rated power means the maximum continuous rated power output as specified on the nameplate and in

the Technical File of the marine diesel engine to which regulation 13 of Annex VI and the NO

Technical Code apply.

Rated speed is the crankshaft revolutions per minute at which the rated power occurs as specified on

the nameplate and in the Technical File of the marine diesel engine.

Brake power is the observed power measured at the crankshaft or its equivalent, the engine being

equipped only with the standard auxiliaries necessary for its operation on the test bed.

On board conditions means that an engine is:

1. installed on board and coupled with the actual equipment which is driven by the engine; and

2. under operation to perform the purpose of the equipment.

A technical file is a record containing all details of parameters, including components and settings of

an engine, which may influence the NO„ emission of the engine, in accordance with 2.4 of the NO„

Technical Code.

A record book of engine parameters is the document for recording all parameter changes, including

components and engine settings, which may influence NOR , emission of the engine.

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GUIDANCE NOTES ON


FROM SHIPS

APPENDIX 5 Interim Guidelines for theApplication of the NO Technical

Code

MEPC/Circ.344

November 1998

Original: ENGLISH

1. The Conference of Parties to the International Convention for the Prevention of Pollutionfrom Ships, 1973, as modified by the Protocol of 1978 relating thereto, held from 15 to 26

September 1997 in conjunction with the Marine Environment Protection Committee's

fortieth session, adopted under Conference Resolution 2, the Technical Code on Control of

Emission of Nitrogen Oxides from Marine Diesel Engines (The NO Technical Code).

2. The purpose of the NOx Technical Code is to establish mandatory procedures for the testing,

survey and certification of marine diesel engines which will enable engine manufacturers,

ship owners and Administrations to ensure that all applicable marine diesel engines comply

with the relevant limits for emission values of NO, as specified in regulation 13 of Annex VI

to MARPOL 73/78.

3. It is noted that regulation 13 of MARPOL Annex VI is intended to be effective on or after 1January 2000. While enforcement of the requirements are not feasible before entry into force

of the Protocol of 1997, it should be clearly understood that engines installed on ships

constructed on or after 1 January 2000 or engines which undergo a major conversion on or

after 1 January 2000 but before entry into force, will have to meet these requirements once

the Protocol enters into force.

4. To allow uniform application of the Code, and to assist Administrations in certifying engines

in accordance with it, prior to the date of entering into force of Annex VI, the guidelines

attached as an annex to this Circular are recommended to be used.

ABS GUIDANCE NOTES ON PREVENTION OF AIR POLLUTION FROM SHIPS. MARCH 19993



GUIDANCE NOTES ON


FROM SHIPS

APPENDIX 6 Check Sheet for an Engine

Parameter Check Method

(Refer to 6.2.3.5 of the NO Technical Code)

For some of the parameters listed below, more than one possibility exists for demonstrating

compliance. In such cases any one of, or an combination of, the listed methods may be sufficient to

show compliance. Approved by the Administration, the ship operator, supported by the engine

manufacturer, may choose which method is applicable.

Parameter Description

Complies with

Technical File

Injection Timing

(see Note I)

1 1 1 1 • 1 1 1 1 1 1 1 1 1 1 1 1 1 1 • 1 1 1 1 1 1 1 1 1 1 1 1 • 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 2 3 1 1 1 NO N/A1.

uelam posit ion or posit ion of a link between the cam and the pump drive (see

Note 2) .

• ViT index and cam position or position of the barrel (for sleeve

metered pumps).

• Other sleeve meter n • devicelease s ec..11Stan of delivery for certain fuel rack positions.(drruc .ressure measurement)

M

111111111111111

M=

Opening of injection valve for certain load points.e.t. usin_ a Hall sensor or accel eration I ic k u.)

• Load-dependent operating values (see note 3):

Charge air p ressure

• Combustion peak p ressure

• Charge air temperature

• Exhaust •as temperatureMl

In ection nozzle So ecification and comtonent identification number.

Injection pump Compo nent identification number.(includin• s ecification forer and barrel desi

Fuel cam I I• ' =HM=

11111

2 .tart and end of delivery for a specified fuel rack position. (dynamic pressure

measurement)

In ectionessure Load- dependent •ressure in the rail (see Note 4 . 11111111111111Combustion

Chamber

Compo nent identification numbers for:ylinder Head

Piston head IMIIIIMllIIIIIICompression ratio 1. Check for actual clearance Ml. Check for shims in piston road or connection rod

ABS4 GUIDANCE NOTE S ON PREVEN TION OF AIR POLLUTION FROM SHIPS, MARCH 19997



Appendix 6O Verification Parameter Check List

Parameter Description

Complies

Technical

with

File

YES NO N/A

Turbocharger

(type and build)

1. Model and specification (identification numbers)

2. Load-dependent charge air pressure (see Note 5)

Charge air cooler,

Charge air

pre-heater

i.

odel and specification

2.

oad-dependent charge air temperature corrected to reference conditions (see

Note 5)

Valve timing

(see Note 6)

1. Cam position

2. Check actual timing

Water injection

(see Note 7)

1. Load dependent water consumption

Exhaust gas

Recirculation

(see Note 7)

I .oad-dependent mass flow of recirculated exhaust gas.

2. CO, concentration in the mixture of fresh air and recirculated exhaust gas (i.e.

in the "scavenge air").3. 02 concentration in the-cavenge air"

Emulsified fuel 1. Load-dependent fuel rack position.

2. Load-dependent water consumption.

Selective catalytic

reduction (SCR)

(see Notes 7 & 8)

Load dependent mass flow of reducing agent and additional periodical spot checks

on NOx concentration after SCR.

Note 1:

Note 2:

Note 3:

To assess the actual timing, it is necessary to know the allowable limits for meeting the emission

limits or even graphs showing the influence of timing an NOx , based on the test bed NO,measurement results.

Position of individual cam, or camshaft if cams are not adjustable

Actual values should be compared with a graph showing the correlation of NO versus the

individual variable. Additionally, the compression ratio is to be eolithied as corresponding to

the initial certification value.

Note 4:ommon rail systems only - actual pressures should be compared with a graph showing the

correlation of NO versus injection pressure.

Note 5:ctual values should be compared with a graph showing the correlation of NO x versus the

individual variable.

Note 6:

nly applicable for 4 stroke engines with inlet valve closure before BDC.

Note 7:

or assessment, values (monitored/recorded) should be compared against a graph showing the

variables influence on NOR .

Note 8:or engines with selective catalytic reduction (SCR) without feedback control, optional NO x

measurement (periodical spot checks or monitoring) is useful to show that the SCR efficiency

still corresponds to the state at the time of certification regardless of whether the ambient

conditions or the fuel quality led to different raw emissions.

78BS'" GUIDANCE NOTES O N PREVENTION OF AIR POLLUTION FROM SHIPS, MARCH 1999

Guidance Notes on the Prevention of Air Pollution From Ships

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