MARPOL ANNEX VI AMENDMENTSPRACTICAL CONSEQUENCES

Tripartite Meeting

BeijingCCS HeadquartersNovember 8/9, 2008

AMEDMENTS

• New regulation on SOx and PM• Primary compliance through fuel• Alternative methodologies (e.g. scrubbers)

accepted as Equivalent Measures (first to be approved by Administrations)

• Marine fuel oil quality to be further improved• No measures on ships that do not receive

adequate supply• if BDN data is challenged by PSC or test

results - Guidelines how to assess compliance • NOx Tier I on large engines from the 1990s• NOx Tier II and Tier III on new engines

GENERAL ASSESSMENT OF THE AMENDMENTS

• Long term predictable regulations

• Global reduction of ship air emissions

• Challenging but Realistic and Feasible

• BUT practical consequences need to be carefully assessed

FUEL-SULPHUR CONTENT

4

MORE ECAs (?)

Planned new ECA for 2013

Could be extended to entire N. A.

Up to 200 nm on the West Coast

Plan to require 0.1% or 0.2% S fuels

FUEL CHANGE OVER OPERATION

• Ships may use 2 or 3 fuel types/voyage

• Need for greater and diversified (segregation) of bunker tanks & pipelines to operate 3 different grades of bunkers

• If not, long time fuel change over period with loss of expensive grade bunkers

• Need for 2 or 3 differing cylinder lube oil systems

FUEL CHANGE OVER OPERATION

FUEL CHANGE OVER OPERATION

• Risk of incompatibility between differing grades of bunker during change over

• Increased average density• Fuels with reduced ignition/combustion

quality• Increased problems with chemical waste

(liquid waste with low/no sulphur used as blend to “make” the LSFO)

• Increase in average cat fines level (Al+Si)

LOW-SULPHUR FUEL OPERATION

Source: DNVPS database of 1,012 analysis results (from 1 October – 10 November 2007)

A reduction of the low-sulphur content in HFO has seen a corresponding increase in the abrasives content

FUEL OIL QUALITY

• IMO Secretariat invited ISO to consider a revision of a marine fuel oil specification (ISO 8217) addressing :

-air quality,

-ship safety,

-engine performance,

-crew health

with recommendations for future consideration by the IMO

possible PRACTICAL CONSEQUENCES

• Better Fuel Quality in a new ISO 8217• ISO is an industry standard• IMO to decide on its enforcement• Ship operators could share experience

with Flags and demand assistance• Would all this accelerate the transit

back to simpler and safer uni-fuel operation on world wide basis?

ENFORCEMENT (PSC & Flag)(today’s practice)

• Most PSC target controls on:– Bunker Delivery Note (BDN)– Availability of the MARPOL fuel sample– fuel change-over recordings in log books (ships need

written fuel change-over procedures)

• Some PSC:– requires to see commercial fuel test reports and

make a decision– take fuel samples from service tanks

• ADVICE: only the MARPOL fuel sample is to be used to test sulphur level

ENFORCEMENT (PSC & Flag)(today’s practice)

• Many Flags do not respond to ship Notifications on non-compliant fuel delivery

• Not unified interpretation for sulphur content limit, e.g.: 1.50%, 1.54%, 1.58%....

• However, ships may not be liable if records & evidence on Fuel Availability are strictly maintained

REVISED REGULATION 18

• Authorities shall take all reasonable steps to promote the availability of fuel oils to comply with Annex VI

• If compliant fuel not available, ships not required to delay departure or deviate from the planned voyage

• The ship will have to notify its Administration and the relevant port of call each time it cannot find the compliant fuel

• The ship should present evidence/record it attempted to buy the compliant fuel in accordance with the voyage plan

• If evidence is provided, there should be no measures against the ship

REVISED REGULATION 18

Evidence/records/actions taken by ships:

(a) Bunker quotation/correspondence

(b) Voyage plan

(c) Bunker Delivery Note (BDN)

(d) Fuel Quality Test report

(e) Notification to Flag, Port Authority & PSC

(f) Report/indication that obtaining compliant fuel will cause deviation/or undue delay

REVISED REGULATION 4EQUIVALENT MEASURES

• An Administration may allow any alternative method only if this is at least as effective in terms of emission reduction as the emission reduction by using LSFO

• This means the Administration (and not the ship) has to acknowledge the alternative methods:– have equivalent efficiency in terms of SOx, PM &

NOx– do not harm the environment – operate within the requirements of the IMO

guidelines

NOx EMISSIONS – UPGRADE ON PRE-2000 ENGINES

• Retroactive measures on engines:– installed onboard ships constructed between

1 Jan 1990 and 31 Dec 1999– power output > 5,000 kW; and – per cylinder displacement at or > 90 litres

• NOx emissions at Tier I level

• If the engine already meets Tier I NOx emission limits, simple certification is sufficient

• One time certification (?)

NOx EMISSIONS – UPGRADE ON PRE-2000 ENGINES

• If the engine does not meet the Tier I NOx emission limitations, it is subject to measures:– ONLY if there is an upgrading system certified by a Party

to MARPOL Annex VI– ONLY if it certifies that such a system reduces the

emissions of that particular engine to Tier I limits– the upgrading system is considered commercially

available 12 months after a Party to MARPOL Annex VI deposits the notification on certification to IMO

– upgrade at the ship’s first renewal survey after the upgrading system becomes commercially available

– in case the upgrading system is not available at the time of completion of the renewal survey (ship owner has to document that), the flag would give an extension until the next Annual Survey

– engine manufacturers concern whether can meet the numbers of bookings for existing and new engines

NOx EMISSIONS – UPGRADE ON PRE-2000 ENGINES

• The upgrading system should not– decrease the engine rating by more than 1%,– increase fuel consumption by more than 2%– have other adverse effect on the durability or

reliability of the engine

• Upgrading to an acceptable cost/benefit

Cost of approved method x 10**6Ce =

P(kW) x 0.768 x 6000 hr/yr x 5 years x Δ NOx (g/kWh)

Ce < 375 SDR/metric ton of NOx reduction; SDR = Special Drawing Rights; 1 SDR = US$ 0.632

Ce < $237/metric ton of NOx reduction

NOx Kit Retrofitting Prices - IMO Maximum

0

100,000

200,000

300,000

400,000

500,000

600,000

700,000

800,000

10% 20% 30% 40% 50%

NOx Reduction

5000 kW

8000 kW

12000 kW

15000 kW

NOx Kits – IMO Max. Costs (US$)

NOx EMISSIONS – Tier II

• Applies to engines installed on ships constructed on and after 1 January 2011

• Tier II standards (reductions related to Tier I):– 15.5% reduction (engines with n<130 rpm) (i.e. 14.36

g/kWh)– reductions between 15.5% & 21.8% depending on

the engine’s rpm (engines with 130 rpm < n < 2000 rpm)

– 21.8% reduction (engines n > 2000 rpm) (i.e. 7.66 g/kWh)

• Engine manufacturers developed such engines

IMO NOX Limitations

Now

1 Jan. 2011

1 Jan. 2016

23

Mark 9 8 7 6bore stroke mech.

S 26 980 MCL 35 1050 MCS 35 1400 MC upgS 35 1550 ME-BS 40 1770 ME-B = Engines in our 2008 ,Tier 2 programS 42 1764 MC upg = Engines which will be available in Tier 2 executionS 46 1932 MC-C ME-B upg but with modified components of the combusion chamber.S 50 1910 MC = Engines which will not be offered in Tier 2 performance..S 50 2000 MC-C ME-C ME-B upgS 50 2214 ME-B inco = Inconel claddingL 60 2022 MC-C ME-CS 60 2292 MC upg = Up-graded combustion chamber geometriS 60 2400 MC-C ME-C ME-B upgS 65 2730 ME-CL 70 2360 MC-C ME-CS 70 2674 MCS 70 2800 MC-C ME-C upgK 80 2300 MC-C ME-CK 80 2600 ME-CS 80 3056 MCS 80 3200 MC-C ME-C incoS 80 3450 ME-CK 90 2300 MC-CK 90 2870 MEK 90 2600 ME-CS 90 3188 MC-C ME-C incoK 98 2400 MC-C ME-C incoK 98 2660 MC ME incoK 108 2660 ME-C

electronic

Marine Engine Programme 2008Tier II Compliance

Source: MAN Diesel

NOx EMISSIONS – Tier III

• Tier III standards – 80% reductions from Tier I limits, applicable when ships in ECA only

• Tier III limits apply to engines:– installed on ships constructed on & after 1

Jan 2016– power output of > 130 kW

(but engines between 130 kW – 750 kW may be exempted by the Administration)

• Outside ECAs - Tier II limits only

PRACTICAL CONSEQUENCES

• Latest from engine manufacturers – possible solution through in engine technology

• If compliance through SCR– existing SCR technology not efficient at low engine loads– compliance might not be achieved across ECAs (i.e. close to

port, through estuaries and straits ships slow down)

• Engine manufacturers to demonstrate compliance• Class/Administration to certify• BUT, in the long run, how would be Tier II

compliant ships (delivered between 2011 and 2016) be treated in ECAs?

• Good advice: if possible, plan for Tier III compliant ships as from 2011

REGULATION 15VOLATILE ORGANIC COMPOUNDS

• All tankers carrying crude oil shall have on board an approved VOC-Management Plan describing all the procedures the ship is applying in order to minimize the emissions of VOC

• No requirement for equipment or technical installations to limit the emissions