2 Governing Regulations MARPOL Annex VI entered into effect in 2005Baltic Sea - SECA from May 2006North Sea - SECA in November 2007Europe Sulphur Directive (1999 & Rev) governs inter alia emissions in port (0.1% S at berth)California (CARB) new regulations which take effect in 2007Various ports are facing new local regulations on Ship Emissions, which are inhibiting future expansion/development
3 Control of Air Pollution from Ships and its Current Revision process MARPOL – Annex VIControl of Air Pollutionfrom Shipsand its Current Revision process
4 Air Emissions from Ships Covered by Annex VIOxides of Nitrogen (NOx) – create OzoneSulphur Oxides (SOx) – create acidificationHydrocarbons (HC) – gas, soot and some particulatesVolatile Organic Compounds (VOC)Refrigerant GasesNot covered (currently) by Annex VICarbon Dioxide (CO2)Carbon Monoxide (CO)Engine exhaust gases are dependent upon engine type, engine settings and fuel type
5 The Regulations in Annex VI There are 19 Regulations but the following Regulations impact Vessel operation :Regulation 12 – Ozone Depleting SubstancesRegulation 13 – NOx emissionsRegulation 14 – Sulphur Oxide emissionsRegulation 15 – VOC emissionsRegulation 16 – Shipboard IncineratorsRegulation 18 – Fuel Oil Quality control
6 IMO Annex VI revision process MEPC 53 (July 2005) – Decided Annex VI be revisedMEPC 54 (March 2006) – Proposals for revision. Delegated work to BLG Sub-CommitteeBLG 10 (April 2006) – Initial review of proposals and documents (over 30 documents)Two correspondence groups (April – October 2006)Intersessional Meeting (November ) – discussion of key issues and draft proposalsBLG 11 (April 2007) – finalize draft proposals for revised Annex VI, the NOx Code and related GuidelinesMEPC 56 (July 2007) & MEPC 57 (March 2008) - consider and approve(?) the revised textsTarget date for Entry in to Force: 2010
7 Many proposals for significant amendments to Annex VI Lower limits for SOx & NOx emissionsSECAs with lower S cap (1% or 0.5%)NOx emission limitation on existing engines, particularly those installed after Jan. 2000NECAs – NOx controlled areasRestriction on CO2 emissionsRestriction on Particulate Matters (PM) emissionsRestriction on VOC emissions from cargo oil tanks
8 INTERTANKO ProcessReviews within ISTEC and Bunker sub-committee over many years – with new emphasis since 2005Ongoing contacts with other stakeholdersReviewed with Executive Committee (June 2006) - basis emphasis on IMO Intersessional meeting in November- Decision that INTERTANKO should contribute actively to the revision process- Secretariat to develop a position paper for submission to IMO, in conjunction with ISTEC for technical and operational evaluationReviewed draft submission with Executive Committee (September 2006)- Decision to support submission to IntersessionalInformal discussion with RT since mid-yearJoint reviews with INTERCARGO’s CASTECInvitation to RT to co-sponsor submission immediately after agreed by Executive Committee
9 Guiding PrinciplesExecutive Committee (June 2006) – Approach to revision processprevent fragmented regulationspromote establishment of a global standard for at sea, coastal and at berth operations (maybe no SECAs)international standards via IMOregulations based on a fuel standard rather than an emissions performance standard, and thus reduce the onus of responsibility on the owner/operator for verification and compliance (sympathy for use of clean fuels / distillates only)
10 Guiding PrinciplesExecutive Committee (June 2006) – Principles for an INTERTANKO position:ensure a solid platform of requirementsbe realistic and feasibleseek a long term and positive reduction of air emissions from ships, andcontribute to a long term and a predictable regulatory regime
11 Owners’ Concerns Multitude of differing requirements Additional requirements for multi-fuel usage
14 Owners’ Concerns Multitude of differing requirements Additional requirements for multi-fuel usageAvailability of appropriate fuelsAvailability & reliability of fuel processing / emission equipmentAdditional costs / possible cost recovery mechanisms
15 Owners’ Concerns Multitude of differing requirements Additional requirements for multi-fuel usageAvailability of appropriate fuelsAvailability & reliability of fuel processing / emission equipmentAdditional costs / possible cost recovery mechanismsOnus of responsibility for verification and compliance
16 Owners’ ConcernsWho bares responsibility for monitoring, verification and compliance ?Owner for:Combustion processExhaust gas emission standardsDisposal of by-productsORFuel supplier for:Quality of fuel supplied
17 Alternative Approaches Do nothing – retain HFO for deep seaExtend SECAsGlobal SECAEstablish local SECAsEstablish NECAsUse technological solutions – catalytic converters, scrubbers and/or filtersBurn distillates close to shoreCold ironingEmissions trading
18 INTERTANKO Approach TABLING FOR DISCUSSION: The use of distillate fuels, with a global S content cap introduced using a two tiered programme, as follows:from , a maximum of 1.00% S contentfor ships’ engines installed on and after , a maximum [0.50]% Sulphur contentA Global Sulphur Emission Control AreaIf the above two issues were considered feasible, then the provisions for checking and monitoring compliance with Regulation 14 and 18 should be revised accordingly.
19 Objective of INTERTANKO submission The main purpose of the INTERTANKO submission is to "present issues that merit further discussion by the IMO Working Group when considering the revision of Annex VI of MARPOL" INTERTANKO believes that it is important that there is open debate at the international level on the subject of how best to meet rapidly changing expectations for lower ship emissions and that there should be full and frank discussion of the various solutions possible.
20 INTERTANKO Approach ITEMS FOR DISCUSSION include: Future production of distillates & time frameConfirmation of switch-over implicationsCosts of engine conversionsNet benefitsFuture costs of distillates
21 Alternative Approaches ITEMS FOR DISCUSSION include:Future production of low sulphur fuels & time frameProving of / reliability of SCR and scrubber technologiesCosts of extra bunker tanksCosts of manifold modifications / samplingCosts of additional maintenanceMeans of disposing of wash water and scrubbed by-productsSuitability of blended fuelsNet benefitsFuture costs of low sulphur HFO/IFOs
22 Where to debate ? IMO Or Series of bilateral discussions External forums with all stakeholders
23 DISTILLATES - ADVANTAGES reduces all types of air emissions from ships, including PMreduces the bunker consumption (by weight) by 5% to 10%eliminates the need of retrofitting of additional bunker storage capacity and associated pipingeliminates current onboard fuel treatment plants and significantly reduces onboard generated ER waste and exposure of the engines to damaging materials
24 DISTILLATES - ADVANTAGES eliminates the need for scrubbers for the inert gas systemno additional costs of installing, operating and, maintaining/repairing equipment for reducing PM and SOx emissionsno potential losses due to delay in case of unexpected breakdown of onboard technologyif no SECAs, no operational burdens for ships & no associated risks when changing fuel types, lube oils and settings for the ship’s engines
25 ONE Approach for CALIFORNIA Environmental achievements 2006Maersk Line announced a pilot environmental initiative that annually reduces vessel-related emissions from the company’s fleet that calls the ports of Los Angeles and Oakland, USA. Maersk Line has voluntarily switched to low-sulphur diesel on the main and auxiliary engines of its vessels when they are within 24 miles of the port and alongside. Maersk Line projects a 73% annual reduction in particulate matter and a 92% reduction in sulphur dioxide (SOx).
27 Regulation 14 - SOxThe Worldwide Sulphur cap on fuel oil is set at 4.5%.Sulphur Emission Control areas (SECAs)Areas – Baltic, North Sea and English ChannelSulphur Level of fuel – 1.5% or;Alternatively use an exhaust gas cleaning systemShip must have cleared all pipe systems and tanks and be using low sulphur fuel on entry
28 Proposed Revisions of Regulation 14 - SOx Reduction of SOx emissionsReduction of the Global Cap – e.g. to 3.00%Reduction of the SECA Cap – e.g. to 1.00% or 0.50%Correction for the reporting and measurement standard to two decimal places for Sulphur content (Bunker Delivery Note criterion).
29 Regulation 13 – NOxFor all Engines (except emergency engines) installed on ships after 1st January 2000 of more than 130 kW must comply to this Regulation.The NOx emission is limited to 17 g/kW h for engines operating at 130 rpm but reducing to 9.8 g/kW h for 2000 rpm. Between these revs the limit is designated by equation:45 * n(-0.2) g/kW hExisting engines can become a “new” engine if substantially modified.
30 Proposed Revisions of Regulation 13 - NOx Tiered approach to further NOx reductions – Tier 2 from date of revisions coming into force , and Tier 3 from 2015Lower limit NOx emissions ( % reduction discussed for first tier – 2010)Further NOx emission limitation on all existing engines, particularly those installed after Jan. 2000NECAs – NOx emission control areas (Tier 3 levels for these areas?)
31 New Parameter for Air Pollution Control Particulate Matter Emission controlWhat are these Particulates?Sulphates from SOxNitrates from NOxVOC from uncombusted hydrocarbonsHeavy Metals e.g. Vanadium, Nickel, Aluminium, Sodium, Calcium, Zinc; from Heavy Fuel oil and Lube OilSoot – from the aromatics in heavy fuel oil
32 Particulate Matter Regulation and Control Methods At present this subject matter has not been fully debated within the working groupIssues to be confronted:Size of the Particulate to be regulated – 10 micron or 2.5 micronExtent of limitation of Particulate emissionMethods for control of Particulate emissions – e.g. Scrubbers and/or FiltersStorage and Disposal of ParticulatesControl and verification of reduced emissions
33 Current Regulation 18 – Fuel Oil Quality “Fuel oil shall be blends of hydrocarbons derived from petroleum refining”“Fuel oil shall be free from inorganic acid”“Fuel oil shall not include any added substance or chemical waste which either:Jeopardises the safety of ships or adversely affects the performance of the machinery, orIs harmful to personnel, orContributes overall to additional air pollution”
34 Regulation 18 – Fuel Oil Quality Bunker Delivery Note (BDN)Becomes a Statutory documentMust be kept on board for 3 years for inspection and a copy taken for further examination.Must contain all data required by appendix VName and IMO number of vesselPortDate of Commencement of deliveryDetails of fuel oil supplierProduct name, quantity , Density at 15 0C and Sulphur content % m/mA declaration that fuel supplied meets Regulation 14 and 18.
35 Regulation 18 – Fuel Oil Quality Fuel Oil SamplingA sealed sample meeting the requirements in associated guidelines has to given to the ship by the bunker supplierFor each individual BDN a sample has to be taken at the vessel’s bunker receiving manifold. (see procedure in associated guidelines)The sample label has to be signed by both the bunker supplier’s representative and the vessel’s Chief Engineer.The sample size shall be not less than 400 mlsThe sample is not to be used for any commercial purposeThe sample is to be retained on board for at least 1 year for inspection by PSC as required