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MARPOL 73/78 Annex VIRegulations for the Prevention of Air Pollution from

ShipsMARPOL 73/78 Annex VI Regulations for the prevention of Air Pollution from ships came into force from !

Ma" #$$%

&he a'option of MARPOL Annex VI has follo(e' some "ears of 'e)ate (ithin organisations* Atthe same time IMO &echnical co'e on the +ontrol of ,missions of -itrogen Oxi'es from Marine .iesel,ngines (as a'opte'* MARPOL Annex VI an' the &echnical +o'e have retroactive reuirements for 'ieselengines 3$ 01 an' a)ove installe' on ships 2eellai' on or after 4anuar" #$$$5 an' Incineratorsinstalle' on)oar' on or after 4anuar" #$$$*

MARPOL Annex VI (ill appl" to all ships5 fixe' an' floating 'rilling rigs an' other platformsfrom ! Ma" #$$%5 )ut the certification reuirements are 'epen'ing on si6e of the vessel an' time of

perio'ical surve"*

hips of $$ gross tons an' a)ove engage' in international vo"ages involving countries that

have ratifie' the conventions5 or ships fl"ing the flag of those countries5 are reuire' to have an

International Air Pollution Prevention ertifi!ate "IAPP ertifi!ate#*

&his certificate must )e on )oar' at 'eliver" for a ship constructe' 92eel lai': after ! Ma"#$$%*

;or ships constructe' )efore this 'ate5 the IAPP certificate must )e on )oar' at the firstsche'ule' 'r"'oc2ing after ! Ma" #$$%5 )ut not later than ! Ma" #$$8*

&he IAPP certificate (ill )e issue' follo(ing an initial surve" carrie' out )" the ;lagA'ministration or )" a recognise' organi6ation 9e*g* .et -ors2e Veritas: on )ehalf of the ;lag

A'ministration5 confirming compliance (ith MARPOL Annex VI* ;or ships (ith the flag of an A'ministrationthat have not "et ratifie' Annex VI5 a ertifi!ate of omplian!e $ith Annex VIma" )e issue' )" .-V*

Annex VI also reuires 'iesel engines 9as 'escri)e' a)ove: to carr" in'ivi'ual certificates (ithregar' to -Ox emissions5 name' %ngine International Air Pollution Prevention "%IAPP#ertifi!ates*

Annex VI requires that every ship of 400 gross tonnage or above and every fixed and floating drillingrig and other platforms shall be subject to the following surveys:

An initial survey before the ship is put into service or before the IA !ertificate is issued for

the first time"

eriodical surveys at intervals specified by the Administration# but not exceeding five years"

A minimum of one intermediate survey during the period of validity of the certificate"

In the case of ships of less than $$ gross tons5 the A'ministration ma" esta)lish appropriatemeasures in or'er to ensure that Annex VI is complie' (ith*&he A'ministration shall arrange for unsche'ule' inspections 'uring the perio' of vali'it" of thecertificate* If the A'ministration esta)lishes man'ator" annual surve"s5 these unsche'ule' inspectionsshall not )e o)ligator"5 an' for this purpose .-V has so far consi'ere' that all A'ministrations (ill appl" as"stem (ith man'ator" annual surve"s*

Annex VI has requirements to the following main issues# which will be highlighted more in detail inthis paper"

$egulation %& ' (missions from )*one depleting substances from refrigerating plants and fire

fighting equipment"

$egulation %+ ' ,itrogen )xide -,)x. emissions from diesel engines

$egulation %4 ' /ulphur )xide -/)x. emissions from ships

$egulation % ' Volatile )rganic compounds emissions from cargo oil tan1s of oil tan1ers

$egulation %2 ' (missions from shipboard incinerators"

$egulation %3 ' uel )il quality"

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Appli!ation for ships &eel'lai( )efore * +anuar, -...

hips constructe' 92eellai': )efore 4anuar" #$$$ nee' to compl" (ith operational reuirements in

MARPOL Annex VI from ! Ma" #$$%*

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where n ; rated engine speed -cran1shaft revolution per minute. and the emission of nitrogen oxidesare calculated as total weighted emission of ,)&

&he ta)le )elo( illustrates the allo(a)le -Ox emissions from 'iesel engines@

ertifi!ation an( on)oar( verifi!ation

&he %IAPP "%ngine International Air Pollution Prevention# !ertifi!ate is reuire' for all 'iesel

engines as 'escri)e' a)ove5 an' (ill )e issue' for marine 'iesel engines after 'emonstrating compliance(ith -Ox emission limits* &he certification process is to )e carrie' out in accor'ance (ith the 0Ox

1e!hni!al o(eissue' )" IMO*he following engines require (IA !ertificates:

(ngine power output above %+0 15

Is the vessel constructed -1eel laid. before or after % 6anuary &000s echnical ile" he below list shows typical ,)x'influencing parameters:

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Injection timing

Injection system components -no**le# injector# fuel pump.

Injection pressure

!amshaft components -fuel cam# inlet' and exhaust cam.

Valve timing

!ombustion chamber -piston# cylinder head# cylinder liner.

!ompression ratio -connecting rod# piston rod# shim# gas1ets.

urbocharger type and build -internal components.

!harge air cooler?charge air pre'heater

Auxiliary blower

,)x reducing equipment @water injection@

,)x reducing equipment @emulsified fuel@ -fuel?water emulsion.

,)x reducing equipment @exhaust gas recirculation@

,)x reducing equipment @selective catalytic reduction@

he actual echnical ile of an engine may include less components and?or parameters other than thelist above# depending on the particular engine and the specific engine design"

One of the main conseuences of MARPOL Annex VI is that the on)oar' verification proce'ureB,ngine parameter chec2 metho'B reuires i'entification mar2ings on the -Ox influencing components*

&hese components are t"picall" those specifie' in a)ove list* All the components liste' are to )e fitte'(ith i'entification mar2ings accor'ing to the &echnical ;ile* Please note that these mar2ings ma" not )ethe same as the article nos usuall" foun' on the engine components 9spare parts num)ers5 serial

num)ers:* It ma" )e the case that parts are availa)le )uilt un'er liscence* &hese must )e stampe' (iththe same num)er other(ise the" are not accepta)le* &hese parts must )e accepte' )" the A'ministrationoverseeing the issue of certification*

&here ma" )e situations (here the engine ma2er comes up (ith a ne( 'esign for one of the-Oxinfluencing components5 (ith a 'ifferent I' -o from (hats state' in the &echnical ;ile* &he ne('esign shoul' then )e approve' )" the A'ministration 9or .-V on )ehalf of a ;lag A'ministration (hen

authorise': an' the change is to )e 'ocumente' in the Re!or( )oo& of engine parameters* &he sameis applica)le for all other changes the engine ma" )e approve' for 'uring its lifetime*

Simplifie( measurement metho(

&his involves full loa' running of the engine for a)out #$ minutes5 an' (ill in most casesreuire a test trial*

.ue to the possi)le 'eviations (hen appl"ing the simplifie' measurement metho'5 anallo(ance of $C of the applica)le limit value is accepte' for confirmation tests an' 'uring perio'ical an'interme'iate surve"s*

4ire!t measurement an( monitoring metho(

&he shipo(ner (ill have the option of 'irect measurement of the -Ox emissions 'uring theengine operation* uch 'ata can either ta2e the form of spot chec2s logge' (ith other engine operating'ata on a regular )asis an' over the full range of engine operation5 or the" can result from continuousmonitoring an' 'ate storage* .ata must )e ta2en (ithin the last 3$ 'a"s5 an' must have )een acuire'using the test proce'ures given in the -Ox &echnical +o'e* &hese monitoring recor's are to )e 2epton)oar' for at least three months for verification purposes*

&o 'emonstrate the compliance )" the 'irect measurement metho'5 sufficient 'ata shall )e

collecte' to calculate the (eighe' average -Ox emissions in accor'ance (ith the -Ox &echnical +o'e*

It shoul' )e note' that the t(o metho's that involve measuring of the exhaust emissions 'onot inclu'e an" 2in' of i'entification mar2ings of the -Oxinfluencing components*

Surve,s an( inspe!tions

ollowing the regime of the IA certificate# the diesel engines will also be subject for the followingsurveys:

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An initial survey before the ship is put into service or before the IA !ertificate is issued for

the first time"

eriodical surveys at intervals specified by the Administration# but not exceeding five years#

A minimum of one intermediate survey during the period of validity of the certificate"

Annual /urveys -or a lag Administration may instead implement unscheduled inspections as

an alternative to Annual surveys.If the @(ngine arameter !hec1 8ethod@ is the selected onboard verification procedure# thesurveyor will typically want to see:

i. $%&'' ertii*ates or all appli*ale +iesel engines onoar+

ii. &pproe+ e*hni*al iles in*l!+ing noar+ erii*ation pro*e+!re or all the appli*ale+iesel engines onoar+iii. e*or+ ook o $ngine parameters or all the appli*ale +iesel engines onoar+i. ne or all o the i+entiie+ *omponents, settings or operating al!es spe*iie+ in the

engines e*hni*al ile

If the @/implified 8easurement 8ethod@ is the selected onboard verificationprocedure# the surveyor will witness the testing in addition to review the followingdocumentation:

. $%&'' ertii*ates or all appli*ale +iesel engines onoar+i. &pproe+ e*hni*al iles in*l!+ing noar+ erii*ation pro*e+!re or all the appli*ale

+iesel engines onoar+

ii. &ll re*ommen+ations rom engine man!a*t!rer an+ approals rom the &+ministration*on*erning the 6impliie+ eas!rement etho+

iii. est res!lts

If the @=irect 8onitoring and 8easurement 8ethod@ is the selected onboardverification procedure# the surveyor will typically want to see:

i8. $%&'' ertii*ates or all appli*ale +iesel engines onoar+8. &pproe+ e*hni*al iles in*l!+ing noar+ erii*ation pro*e+!re or all the appli*ale

+iesel engines onoar+8i. 9o*!mentation/&pproal o the installe+ meas!ring e:!ipment8ii. ;ogge+ meas!rement res!lts in or+er to eri< that the engines *ompl< with the =8

e*hni*al o+e.

$egardless of what onboard verification procedure the /hip')wner chooses# the IA !ertificate forthe vessel will be issued if all other requirements are found to comply with the applicablerequirements"

%ngines $ith %IAPP !ertifi!ates issue( ), another !ompan,

Although there are several companies a)le to certif" engines onl" those approve' )" flag tate (ill )eaccepta)le to the a'ministration 9generall" +lass: (ho have )een authorise' to issue certification*

Regulation *5 ' Sulphur Oxi(es "SOx#

6eneral

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set forth certain criteria for 'esignating such ,+As*

&he limitations in sulphur content applies to all fuel oils 9heav" fuel oils5 marine 'iesel oils an'

gas oils: an' regar'less of use on )oar' 9i*e* in com)ustion engines5 )oilers5 gas tur)ines etc*:*

+urrentl"5 the average sulphur content in fuel oils is in the region of #*7C (ith onl" $*#C

having ulphur content a)ove *%C* ?o(ever onl" C of fuels have less than *%C*

%xhaust 6as leaning s,stems

As an alternative to using marine fuel oil (ith a *%C sulphur content in ,+As5 an exhaust gas cleanings"stem or other euivalent s"stem ma" )e use' 9a)atement technologies:* &he emission criteria for suchs"stems are > g Ox/21h*

.evelopment of a t"pe approval stan'ar' for such s"stems is ongoing in IMO* &he currentavaila)le a)atement technolog" is )ase' on sea(ater scru))ing principles*

here is however a few concerns related to these types of scrubber type systems:

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Annex VI states that port states may prohibit discharge of scrubber effluent overboard in ports

within /(!A>s unless it can be documented that the effluent complies with criteria set by thatport state" A mitigating measure is installation of filtration?treatment systems"

It has been indicated that conventional scrubber technology may be struggling to meet the

emission criteria at high exhaust gas discharge flows"

It has been indicated that there is a ris1 of blue'sheen originating from the scrubber overboard

discharge" Although# not necessarily constituting an environmental ha*ard# the mere ris1 ofsuch occurrences is to some operators unacceptable"

here are space considerations in the engine room and more specifically the funnel" Although

it has been indicated that the more advanced scrubber types can replace standard silencers#the associated piping systems may represent a challenge" ressure drop in scrubbers hasalso been indicated as a limitation# particular in way of main engines upta1es"

an1er owners have had mixed experiences with corrosion of inert gas scrubbers and

associated piping systems"

he ( has been reluctant to accept scrubbers" Based on trials they have indicated that they

may accept abatement technology as an equivalent to low sulphur fuel" ,ote that ( hasindicated that it will develop criteria for resulting waste streams in their ports"

The author understands that the trial of this scrubbers have been pretty disastrous and have oftenended up being expensive follies

% 4ire!tive */3-/% $ith propose( amen(ments

In connection (ith MARPOL Annex VI one cannot 'isregar' ongoing lo(sulphur 'evelopments in the ,

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It shoul' )e note' that (hen approaching a ,+A the fuel must )e change' over to the *%C sulphurcontent fuel an' complete' )efore entering the ,+A* &hat is all the fuel lines to the engine must havethis fuel onl"*

here are two approaches to this1. ;!shing - low s!lph!re !el is !se+ to l!sh o!t the higher s!lph!r !les rom the

settling/seri*e tank2. 9!pli*ation o tanks- seperate 6ettling/seri*e tanks are installe+ or the two t

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hange'over pro!e(ures

&he time5 ships positions at the start an' completion of changeover to an' from *%C fuel oil must )erecor'e' in a log)oo2 9e*g* ,R log* )oo2:5 together (ith 'etails of the tan2s involve' an' fuel use'* It can)e anticipate' that the same (ill )e applica)le (ith respect to the ,< proposal upon entr" into force*

Regulation *9 : Volatile Organi! ompoun(s

,missions of volatile organic compoun's 9VO+s: from tan2ers ma" )" each part" to Annex VI )e regulate'in its ports an' terminals* uch reuirements shall )e given in a list pu)lishe' )" IMO* &he list shall alsospecif" si6e of tan2ers5 an' (hich cargoes5 that reuires vapour emission control s"stem*

All tan2ers (hich are su)=ect to vapour emission control in accor'ance (ith a)ove list shall )e

provi'e' (ith an approve' vapour collection s"stem5 an' shall use such s"stem 'uring the loa'ing of suchcargoes*

,xisting tan2ers (hich are not fitte' (ith vapour collection s"stems ma" )e accepte' for aperio' of three "ears after the terminal (as inclu'e' in the a)ove list* .-V has for man" "ears ha' class

notations V+ an' # for vapour control s"stems compl"ing (ith IMO Eui'elines 9M+/+irc*%8%:5 an'9$:*

Monitoring of com)ustion flue gas outlet temperature shall )e reuire' at all times an' (asteshall not )e fe' into a continuousfee' ship)oar' incinerator (hen the temperature is )elo( the minimumallo(e' temperature of 8%$F+* ;or )atchloa'e' ship)oar' incinerators5 the unit shall )e 'esigne' so thatthe temperature in the com)ustion cham)er shall reach >$$F+ (ithin % minutes after startup* It must )eensure' that the incineratorsB flue gas outlet temperature monitoring s"stem is operational*

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All incinerators installe' on or after 4anuar" #$$$ shall )e t"pe approve' in accor'ance (ithResolution M,P+ 7>9$: giving the IMO stan'ar' specification for ship)oar' incinerators* ;or suchincinerators a manufacturerBs operating manual is reuire'*

Regulation *8 : 2uel Oil

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MARPOL 73/78 Annex VI fuel oil samples

Regulation 8 reuires that ever" D.- is to )e accompanie' )" a representative sample of the fuel oil

'elivere'5 ta2ing into account the gui'elines in Resolution M,P+*!>97:*

&he sample is to )e seale' an' signe' )" the supplierBs representative an' the master orofficer in charge of the )un2er operation on completion of )un2ering operations5 an' retaine' un'er theshipBs control until the fuel oil is su)stantiall" consume'5 )ut in an" case for a perio' of not less than #months from the time of 'eliver"* Although M,P+*!>97: specifies that the volume of the sample )ottle

shoul' )e no less than $$ ml5 'ue to potential nee' for repetitive testing5 Intertan2o has recommen'e'that the sample volume is not to )e less than 7%$ ml*

;or the sa2e of goo' or'er it shoul' )e note' that the practical purpose of this sample is to

ena)le port states to verif" the sulphur content of the fuel5 as (ell as to verif" that the fuel oil ualit" is inaccor'ance (ith Regulation 8*

As Annex VI specifies that the Annex VI sample is not to )e use' for commercial purposes5.-V Petroleum ervices recommen's that for ships alrea'" participating in a fuel oil ualit" testingscheme5 the Annex VI sample shoul' )e the fourth sample 9in a''ition to the sample sent to la)orator"for testing5 suppliers sample an' the retaine' on)oar' sample:* &he reason is that it is consi'ere' an

a'vantage to al(a"s have an Annex VI sample on)oar' in case of port state controls*

Sampling pro!e(ures

-ote that the referre' to Resolution M,P+*!>97: specifies in 'etail that the fuel sample is to )e o)taine'

at the receiving ships inlet )un2er manifol' an' is to )e 'ra(n continuousl" throughout the )un2er'eliver" perio'* &he term continuousl" 'ra(n is specifie' to mean a continuous collection of 'rip sample

throughout the 'eliver" of )un2er fuel* ampling metho's are further clarifie' as eitherG manual valvesetting continuous'rip sampler 9euivalent to .-V Petroleum ervices Line sampler:5 timeproportionalautomatic sampler5 or flo(proportional automatic sampler*

urther the guidelines specify that sample bottle labels are to contain the following information:

Focation at which# and the method by which# the sample was drawn

Bun1ering date

,ame of bun1er tan1er?bun1er installation

,ame and I8) number of the receiving ship

/ignatures and names of the supplier>s representative and the ship@s representative

=etails of seal identification

Bun1er grade"

Sample inventor,

Resolution M,P+*!>97: also contains recommen'ations on sample storage location*

Supplier>s responsi)ilit,

1hile most IMO conventions place full responsi)ilit" on the ships an' ship o(ners5 Regulation 8 places a

certain responsi)ilit" on the suppliers 9fuel oil ualit" 'eclaration5 D.- an' the Annex VI fuel oil sample )"continuous 'rip an' at the receiving ships manifol':*

Annex VI of 8A$)F also contains instruments to encourage port states to ensure that suppliers fulfiltheir obligations" ort states are therefore required to:

8aintain a register of local suppliers of fuel oil7

$equire local suppliers to provide the B=, and sample# certified by the fuel oil supplier that

the fuel oil meets the requirements of regulations %4 and %3"

$equire local suppliers to retain a copy of the bun1er delivery note for at least three years for

inspection and verification by the ort /tate as necessary7

a1e action as appropriate against fuel oil suppliers that have been found to deliver fuel oilthat does not comply with that stated on the Bun1er =elivery ,ote7

Inform the lag Administration of any ship receiving fuel oil found to be noncompliant with the

requirements of regulations %4 or %3 of this Annex"

Inform I8) for transmission to arties to the rotocol of %CCG of all cases where fuel oil

suppliers have failed to meet the requirements specified in regulations %4 or %3"

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?o(ever5 'espite the suppliers responsi)ilities an' the instruments availa)le5 previousexperience from Port tate +ontrols in'icates that it is a'visa)le for o(ners/managers themselves toensure compliance* In or'er to assist ships in ensuring that the operational reuirements are met5 itshoul' )e consi'ere' to inclu'e clauses relate' to MARPOL Annex VI compliance in )un2er contracts an'agreements (ith suppliers5 as (ell as charter parties*

1hir( part, inspe!tions

It can )e expecte' that upon implementation5 class surve"ors5 port state inspectors an' possi)l" also

vetting inspectors (ill scrutinise on)oar' 'ocumentation an' recor's 9e*g* sampling proce'ures5 changeover proce'ures5 ,R log )oo2s5 D.-Bs5 sample inventor" log )oo2s etc*:5 as (ell as the fuel oil sampleinventor"*

The updated list showing state of ratification can be found on IMO's web pageswww!imo!org"home!asp# under 'conventions' and 'status of conventions by country! $or furtherinformation% please contact& Annex I in general& ()% *argo +andling% ,iping Systems% Marpol and-as *arriers MT,)O../0dnv!com# )Ox and engine related in1uiries&()% Section for machinery% Ships in OperationMT,)O.230dnv!com#()% Section for machinery% )ewbuilding MT,)O4340dnv!com#

SOx and fuel related in1uiries&()% *argo +andling% ,iping Systems% Marpol and -as *arriers MT,)O../0dnv!com#(),S% () ,etroleum Services (),S!OS5O0dnvps!com#