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MARPOL Annex VI-Regulations for the Prevention of Air Pollution The 1999 EC Directive on Fuel Sulphur and amendments. Refrigerants and fire fighting agents current EU and MARPOL legislation. Antifouling paint certification and future regulations. The International Convention for the Control Management of Ships Ballast Water and Sediments. Recycling of Ships, the IMO Guidelines and the Green Passport scheme. Environmental Protection Notation.
January 2005
ANANGEL/KRISTEN/MARAN GAS Training Dept. has been certified by DNV under the provisions of DNV Rules for Maritime Training Centers with a certificate No: 113443.
The 1972 UN Conference on the Human Environment in Stockholm initiated the beginning of active international cooperation in tackling acidification/acid rain. In 1979 the Convention on Long-range Trans-boundary air pollution was signed by 34 Governments and the EU. Protocols to the 1979 Convention were later signed on: Reducing Sulphur emission (1985) Controlling emissions of nitrogen oxides (1988) Controlling emissions on VOC (1991) Further reducing sulphur emissions (1994) The protocol of 1997 (the new Annex VI of MARPOL 73/78)
Health impacts becoming more important & easily measured. Contribution of Shipping to SOx emissions becoming a significant proportion of overall emissions Cost of Sea reductions is less than other options Annex VI is one step to the right direction, however will not resolve the issue of shipping emissions.
Environmental Impact
According to research conducted by IMO sulphur emission from ships exhaust is estimated at 4.5-6.5 Million tones/year=4% of total global sulphur emissions.
Amendments on 1999/32/EC[COM(2002)595)
Designed to be inline with Annex VI-MARPOL 73/78. Maximum 1.5% sulphur limit for fuels used by all ships in the Baltic Sea, North Sea & Channel. Todays political agreement incorporates this provision, and sets implementation dates starting in 19 May 2006 for the Baltic Sea. Maximum 1.5% sulphur limit for fuels used by passenger vessels on regular services between EU ports, from 1 July 2007. EU Ministers also rubber stamped this and brought the deadline forward to 19 May 2006. Maximum 0.2% sulphur limit on fuel used by inland vessels and by seagoing ships at berth in EU ports. The Council agreed a tighter 0.1% limit delayed until 1 January 2010, to allow single-fuel ships time to adapt their fuel tanks. A further two year delay was offered to 16 unifuel ferries serving the Greek islands.
Factors to Consider
Impact on the Bunker Industry (&what this implies??). Impact of the Expansion of EU member states. Availability of Low sulphur fuels. Impact on storage on the ship (for both Fuels & Lubricants) Technical impact, assessment of the impact on the Machinery plant.
emergency or lifeboat engines). Applies from 1 January 2000 delivered ships Variable NOx emission limits dependent upon engine speed. (From 17 gNO2/kWh to 9.8 gNO2/kWh depending on rated engine speed)
Parent Engine Parent engine Measure emissions & establish tolerances on performance data Establish NOx components Measure performance data (Pmax, Pcomp, Tscav, Turbo back pressure) on testbed and establish sensitivity of changes to these parameters to level of NOx emissions
Member Engine Do performance check to ensure all measurements are within the limits established on the Parent testbed results Check and ensure all NOx components are correct and marked as such No need to measure emissions
NOx Components
MAN B&W slow speed engines 11-12 standard engine components selected and marked with their IMO number (usually part no) Fuel nozzle (most influence and easier to check) Fuel pump plunger and barrel Cylinder liner, cylinder cover, piston crown Fuel cam and exhaust cam Scavenge air cooler Auxiliary Blower Turbocharger Governor (as applicable)
A declaration that the fuel oil supplied is in conformity with regulation 14(1) or (4)(a) and 18(1) of Annex VI should be signed by the fuel supplier. The bunker delivery note should be accompanied by a representative fuel oil sample of the fuel delivered to the ship. Guidelines as to how a representative drip sample is obtained are defined in MEPC 96(47). Both the vessel and the fuel oil supplier should retain the bunker receipts for a period of three years after the fuel oil has been delivered to the vessel.
Samples should be retained on board ship for at least 12 months since the day/time of delivery. When operated in SECA zone ships should allow sufficient time prior to change over to low sulphur (<or=1.5%m/m) fuels. The volume of low sulphur fuel in the tank as well as the date, time and position of the ship when any fuel change operation is completed should be recorded in a log book.
1.5% M/M (Max) Sulphur @ SOx Emissions Control Areas (Known as SECA zone) SECA zone includes (Baltic Sea, North Sea & English Channel) Currently the only SECA Zone is Baltic Sea Baltic Sea-12 months grace period after Annex VI enforcement (19/06/2006)
Alternatively ships must fit an Exhaust Gas cleaning system (which can restrict sulphur emissions to 6.0 g/KWh)
Specifically for Uni-fuel HFO ships designed for one fuel type.
Difficult to maintain seal integrity (H.P. Fuel oil P.P) Very low sulphur-Lubricity vulnerable. compounds reduced-Fuel pumps/injectors
Steam plants-Difficulty to adopt to high load boiler operational requirements when operate boilers on Gas Oil (i.e. Discharging conditions) Cylinder Oil Base Number (BN)-to Sulphur content. Implications on change procedures Liner Lacquering-Increased cylinder deposits-bore polishing-loss of oil control.
Effects of Lacquering
Lacquering and polishing may result to increased cylinder lubricating oil consumption.
Higher operational cost. Lubrication may be ineffective resulting to high temperatures and damage of piston rings, liners etc. he problems are more apparent to modern engines operating at high pressures (especially modern medium speed engines with high BMEP (Brake Mean Effective Pressure) Lacquering is more favorable when the engine is operated above MCR (Maximum Continuous Rating) for extended periods with the duty cycle changing from high to low loads.
HFO Blending. Increase Import volumes of Low sulphur crude oil. (Brazil, South America etc). Desulphurisation through the refining process. Fuel Oil/Gas oil tank segregation on board ships. Use low sulphur fuel (e.g. 1.5% M/M max. limit) worldwide. Emission Credit Exchange System.
Cleaning of scrubbing water before discharge Further reductions of NOx & Particulates
Emissions
SOx 90% NOx 15% Particulates 80%
Efficiency
Blending
The fuels blended should be compatible. Can easily result to incompatibility and consequently operational problems on board. May encourage in-line blending during delivery (depending on suppliers policy). Poses increased risk with respect to compatibility and homogeneity compared to non blended fuels. Fuel & Cylinder Lubricating oil segregation.
Time consuming Process. Fuel & Cylinder Lubricating oil segregation. Estimated additional cost will be around 40 $ to 60 USD/MT Increased cost will be due to high cost of Hydro treatment and the high capital cost requirements for hydrogen gas. Increased cost. It is estimated that fuel oil desulphurisation will cost the industry approximately 1 billion $ USD. Who is finally covering the additional cost?
Will affect availability. Increased cost. Highly dependent on OPECs Production Plan. Consideration of Technical issues required.
Conclusions
Both Annex VI-MARPOL 73/78 and the amended 1999/32/EC will have a huge impact on the fuel quality delivered to ships. Fuel suppliers will be forced to supply a better quality fuel. Storage requirements for both fuel oil and cylinder lubricating oil will be affected. Fuel oil cost is likely to increase (Desulphurisation at an extra US$ 40 US$ 60/MT). Additional requirements for both ships crew and shore based personnel. Independent Testing Services may be required for quality assurance.
New ships- ensure Builders working drawings consistent with approved plans. Existing ships-determine applicable requirements. Ensure equipment, system, fittings, arrangements & materials fully comply (with applicable requirements) Survey checklist completed & IAPP Certificate or Certificate of Compliance issued.
MARPOL Annex VI More SECAs? Decreased fuel Sulphur limit globally & in SECAs? Lower engine NOx limits. Additional emission components-particulates? Greenhouse gas (GHG) emissions
Main focus CO2 - directly linked to fuel consumption, international shipping emissions excluded from international agreements. CO2 emissions/tones/mile Ten years time frame
No additional measures at present for NOx-but if no definite measures for further NOx reduction at IMO, EC likely to act. Push to include international shipping in CO2 emissions trading from 2012. VOC emissions considered relatively low than other sources & currently no proposals to regulate.
Terminology
This is the time taken before the released refrigerant decomposes down to its constituent elements. Natural compounds with short atmospheric lifetimes will degrade near their point of release, such as hydrocarbons and ammonia. With CFCs and HCFCs it is only once they reach the stratosphere and the chlorine content is subject to the suns high energy ultraviolet radiation will they start to decompose. This process can last many if not hundreds of years.
This is another relative figure and is the term given to the upward climatic change attributed to CO2, methane, nitrous oxide, CFCs etc. being released into the atmosphere and absorbing infrared radiation which would otherwise escape into space.
The figures are based on the total calculated global warming due to the emission of a kilogram of the refrigerant divided by the total calculated global warming due to the emission of a kilogram of CFC R11.
Ozone Depletion
Not yet fully ratified stalled by United States. Russia has decided to ratify the protocol by this year
Legislation
Current Montreal Protocol covers all ozone depleting substances and their production phase out. Regulation (EC) No.2037/2000 covers ozone depleting substances their use and also emission control (recovery) within EU. EN 378 Refrigeration systems and heat pumps Safety and environmental requirements. Flag State requirements such as Cyprus totally prohibiting the use of ozone depleting substances, such as HCFC R22, on existing ships as from 2008
Enacted
IMO MARPOL Annex VI, Annex VI has been ratified and came into force on 19 May 2005
Regulation 12 specifically targets ozone depleting substances, their deliberate emissions and removal from the ship. Flag State requirements
Proposed Legislation
Kyoto Protocol covers global warming potential from a basket of greenhouse gases. European Climate Change Programme covers emissions and use restrictions of Fluorinated gases, CFCs, HCFCs and HFCs (F-gas Regs)
IMO MEPC 46/INF.29 Prevention of Air Pollution from Ships Recommendations submitted by Friends of the Earth International. Release of hydrocarbons (VOCs) to the atmosphere.
Refrigerants
The charging, topping up and removal of refrigerant from the system or equipment. What is not construed as Use: The circulation of the refrigerant within the system is not considered as use Thus the continued use of CFCs and HCFCs refrigerants in existing systems after their final ban date will not, as of today, be legislated against.
Refrigerants
Existing ships Continue to use HCFC R-22 The use of HCFC R-22 in existing systems will continue to be allowed. Virgin R-22 will continue to be available up to 2010. Recycled R-22 will be available up to 2015. HFCs are, as of today, not legislated against- their use should be restricted when possible.
New construction
HFCs
Unfortunately HFCs, which were original introduced as substitutes for ozone depleting CFCs are extremely powerful greenhouse gases, with a global warming potential many thousand times larger than carbon dioxide. Natural substances Natural substances can not be legislated against Ammonia, apart from being toxic, would be the refrigerant of choice in the majority of industrial applications. Carbon dioxide and hydrocarbons are both good refrigerants.
Conclusions
CFCs are history no refrigerants allowed to be sold, supplied or used.
HCFCs are banned from being supplied in new refrigeration equipment. Still allowed to be used fore servicing existing equipment until 2010, this date will be reviewed not later than 2008. HFCs still promoted as best alternatives when a natural substance can not be readily used. Natural substances carbon dioxide, ammonia, propane and cyclopentane, Free of legislation but possible safety considerations, toxicity, flammability. Alternative technologies.
Replacements for Halons marine applications. Legislation. Decommissioning requirements. IMO, Flag State, Montreal Protocol and European Union involvement.
Halons
Halon 1211 (BFC) used in portable extinguishers & aircraft. Halon 1301 (BTM) used in bulk or flooded marine systems and petrochemical applications. Halons 2402 1011 part of the same Halon group used for feedstock and for fire control. Critical use exception by (EC) regulation 2037 IMO MSC 77/11/1 and especially Flag State involvement regarding continued critical use.
Traditional Detection and manual intervention Water sprinkler systems water mist high fog system Carbon dioxide, dry powder and foam
Man-made gaseous agents Inert gases nitrogen, argon, carbon dioxide or mixtures Halocarbon gases Inert gas generation aircraft only at present Fine solid particle technology Still to be refined
Both HFC and PFC gases had been developed FE13 FE-125 FM-200 FE-36 CEA-308 CEA-410 HFC 23 HFC 125 HFC 227ea HFC 236fa PFC-2-1-8 PFC-3-1-10 Triflouromethane Pentafluoromethane Heptafluoropropane Hexafluoropropane Perfluoropropane Perfluorobutane
Subsequently PFC gases have now been banned by IMO/SOLAS Chapter II-2, Reg. 10, 4.1.3. New alternatives such as Fluorinated Ketone are being developed and marketed under various Trade Names such as NOVEC 1230.
Legislation effects
The HFC alternatives have high global warming potential, from 2,900 to a staggering 11,700.
The Kyoto Protocol will affect gases which have a high GWP. Within the EC the proposed F-gas regulations may require any emissions from the whole family of halocarbon gases to be strictly regulated. Some Flag State have individually restricted the continued use of Halon and they may also has some involvement with the Halon replacements.
Decommissioning
Halon is still available on a worldwide basis to allow the continued safe operation of cargo ships.
IMO FP/Circ.27 Halon banking and reception facilities lists the sites and limitations when Halon will be provided. The decommissioning date for EC Flag State countries was 31 December 2003. However recycled Halon is still available in a number of Member States for critical use systems.
ANTI-FOULING COATINGS
Regulation and Certification
IMO AFS Convention and EU Regulation IMO Convention Current status of the Convention EC Regulation on antifouling systems. Survey, certification and inspection IMO Guidelines Survey, certification and inspection
Anti-fouling coatings
Antifouling paints are applied to the underwater parts of ships or structures to keep the surfaces free of fouling in order to keep surfaces smooth and, consequently, reduce fuel consumption and increase speed.
AFS Convention
The Convention: Bans application of antifouling coatings containing organotin compounds from being applied as biocides from 1 January 2003, and the active presence of organotin compounds on ships hull surfaces from 1 January 2008.
Surveys
MEPC Resolution 102(48): Guidelines for survey and certification of anti-fouling systems on ships adopted on 11 October 2002. MEPC Resolution 104(49): Guidelines for brief sampling of anti-fouling systems on ships adopted on 18 July 2003 MEPC Resolution 105(49): Guidelines for inspection of anti-fouling systems on ships adopted on 18 July 2003.
Document review
Ships details Details of antifouling paints and coating specification (including sealer coat) Previous antifouling coat if not removed.
Survey
On-site inspection to verify compliance of the paint including. Product identification and application witness If necessary, sampling and testing of antifouling paints or coatings.
Certification
EU antifouling certificates. IMO antifouling certificates to be issued after the Convention comes into force. Certificates remain valid until AFS changed.
Why manage ballast water and sediments and why have a convention? The new Convention Ballast water management plans
This introduction can have an effect on human health, cause damage to local marine life and local economies. The effects cost millions of dollars to deal with each year. The effects of unwanted organisms has been known for a considerable time. The United Nations Conference on Environment and Development (UNCED) in 1992, in Agenda 21 called on the IMO to take action to address the transfer of harmful organisms by ships. The IMO have been discussing the issues involved and working towards a convention for more than 10 years.
Use an approved ballast water treatment system that meets the standards of the convention.
BWE to result to at least 95% volumetric exchange of Ballast Water or Pumping through three times the volume of each Ballast Water tank is considered to meet the standard described above. (Pumping through less than three times the volume may be accepted, provided the ship can demonstrate that at least 95% volumetric exchange is met.)
b. Escherichia coli less than 250 cfu per 100 mililitres; c. Intestinal Enterococci less than 100 cfu per 100 mililitres.
A ship is not required to deviate from its intended voyage, or delay the voyage to comply. The master may decide not to carry out exchange: If it would threaten the safety of the ship crew or passengers; Because of adverse weather, ship design or stress, equipment failure; Any other extraordinary condition. If not undertaken the reasons to be entered in the Ballast Water record book.
Vessels constructed in or after 2009 Ballast water capacity less than 5,000m3; Treatment
Vessels constructed between 2009 and 2012: Ballast water capacity more than 5,000m3; Exchange until 2016; Treatment after 2016
Vessels constructed in or after 2012; Ballast water capacity more than 5,000m3; Treatment
For compliance with the Convention NO (except to plan ahead) For compliance with national regulations YES For example Australia, New Zealand, Israel (Red Sea), Canada, Chile, US (federal and individual state).
Control Sediments
Design Considerations
Light and heavy ballast conditions Departure and arrival conditions Propeller immersion Pumping capability Intact stability Bridge visibility Tank design Longitudinal strength Forward draught Dynamic Loads Ballast Sampling Arrangements
Must be safe (For ship and crew) Must be environmentally acceptable Must be cost-effective Must work Must be approved
Approval Requirements
Treatment systems will be required to be approved in accordance with IMO agreed guidelines. The approval guidelines will be adopted in July 2005.
Current research seems to indicate that a combination of two or perhaps more methods may be the solution.
APPROXIMATE OPERATING COSTS Per tonne of ballast (US cents)
Sequential Exchange = 1 Flow through = 2 Heat = 2.5 Filter = 0.5 Cyclone = 0.3 UV = 0.04
Assist in the ship in complying with international regulations to minimize the risk of the transfer of harmful aquatic organisms and pathogens in ships ballast water and associated sediments. Consider ship safety elements. Provide information to PSC/quarantine officers on the ships ballast handling system and to confirm that ballast management can be effectively planned. Include training on BWM operational practices.
Conclusions
An early decision should be made on what BWM method(s) are to be used for new buildings. Ship design should take into account BWM A BWM plan should be produced for ballast exchange operations to safeguard the ship
SHIP RECYCLING
IMO GUIDELINES
Recent history
Industry initiated development of guidelines for inventory of hazardous materials onboard ships.
Fed into IMO discussions and resulting IMO Guidelines on Ship Recycling adopted Dec 2003. The International Labour Organization (ILO) also developed Guidelines which apply to the safety & health of workers in recycling facilities May 2003. The Basel Convention has published, Technical Guidelines for the Environmentally Sound Management of the Full or Partial Dismantling of Ships December 2002. Difficulties of disposing of unwanted tonnage, exacerbated by EU regulations for accelerated phasing out single hull tankers.
To give best practice, adopted 05 December 2003. Voluntary guidelines at present. Implications throughout ship lifecycle existing ships & new builds. Preparation of ship for recycling ship recycling plan.
Through life inventory of potentially hazardous materials Green Passport provided by shipyard. Hazardous materials in ships structure and equipment Operationally generated wastes Stores Preparation for scrapping Selection of recycling facilities Preparation for recycling plan Minimise all residual oils and chemicals onboard
Design out hazards minimize the use of potential hazardous materials Finalized prior to final voyage. Newbuilding Audit yard and sub contractor supply Compile inventory and produce Green Passport Promote waste reduction and/or regeneration
Shipowners actions
Newbuilding program Specify Green Passport for all newbuild contracts Reduce or exclude hazardous materials in contract Audit during construction Existing fleet Compile inventory of hazardous material Submit documentation for approval Verification by survey and issue Green Passport Ships laid waiting to be scrapped Green Passport Preparation for scrapping
Class society environmental rules Cover major operational pollutants Include design, equipment and operational aspects Goes beyond current environmental legislation Applies to new & existing ships
Core requirements
Exhaust emissions (NOx SOx) Oil pollution Sewage Garbage Ballast water Antifouling paints Fire-fighting agents Refrigerants
Supplementary modules
Hull anti-fouling (A) Ballast water management (B) Grey water (G) NOx emissions (N) Oily bilge water (O) Protected oil tanks (P) Refrigeration systems (R) SOx emissions (S) Vapour emission control systems (V)
Refrigerant gases restricted to those having Ozone Depleting Potential (ODP) = 0 Global Warming Potential (GWP)<1950
Oil pollution prevention sludge & waste oil tanks sufficient capacity to store oily wastes between ports. Oily water separator to reduce oil-in-water content of bilge water to 15 ppm or less. Sewage treatment system or holding tanks. Capacity sufficient for maximum number onboard. Various design features (eg. Independent ventilation pipes). Statement of compliance with the requirements of USCG 33 CFR 159 or MARPOL 73/78 Annex IV.
Approval process
Plan & document review Initial survey (and audit) Assignment of EP notation Annual and renewal surveys
Which ships?
Mainly new builds, some existing ships Changing profile of owners and ships seeking EP notation Approx 170-180 appropriate completed or in hand