INTERNATIONAL MARITIME ORGANIZATION
INTERSESSIONAL MEETING OF THE
BLG WORKING GROUP ON AIR
POLLUTION
1st session
Agenda item 2
BLG-WGAP 1/2/XX
17 October 2006
Original: ENGLISH
REVISION OF MARPOL ANNEX VI, THE NOx TECHNICAL CODE AND
RELEVANT GUIDELINES
Submitted by INTERTANKO
SUMMARY
Executive Summary
This paper presents issues that merit further discussion by the
Working Group when considering the revision of MARPOL
Annex VI.
Action to be taken:
Paragraph 29
Related documents:
MARPOL Annex VI; NOx Technical Code; BLG 10/ 14/2;
BLG -WGAP 1& 2
Introduction
1.
INTERTANKO recognises that the requirements of Annex VI to control differing
sources of air pollution from ships could be improved upon due to technical developments in
engines and diverse ancillary equipment. INTERTANKO also believes that the structure and
approach in some of the current MARPOL Annex VI provisions could be revised for easier
compliance, enforcement and monitoring.
2.
Noting that the Organisation has initiated a major revision one year after MARPOL
Annex VI entered into force and based on the experience gained so far with the current rule
application, INTERTANKO is of the view that any revisions to Annex VI should be based
upon the following:




ensuring a solid platform of requirements,
are realistic and feasible,
produce a long term and positive reduction of air emissions from ships, and
contribute to a long term and a predictable regulatory regime.
1
3.
Based on these principles, INTERTANKO believes that the following issues merit a
detailed discussion by the working group:
a) The use of distillate fuels, with a global Sulphur content cap introduced using a two
tiered programme, as follows:
(i) from [2010], a maximum of 1.00% Sulphur content and
(ii) for ships’ engines installed on and after [2015], a maximum [0.50]% Sulphur
content
b) A Global Sulphur Emission Control Area (SECA)
c) If the above two issues were considered feasible, then the provisions for checking
and monitoring compliance with Regulation 14 and 18 should be revised accordingly.
DISCUSSION OF ISSUES
4.
Reduction of Emissions resulting from fuel quality control – Regulation 18 - The
quality of the fuel used by ships has varying impacts upon the extent of emissions. The
emissions from the fuel combustion process can be significantly reduced by the combustion
of cleaner fuels such as the distillate fuels as found in Table 1 of ISO 8217. Ships using a
distillate fuel would achieve reductions of NOx, SOx and the new parameter/criterion,
Particulate Matter (PM).
5.
Reasons: The reasons the above issue should be discussed further are summarized as
follows:
 simple and straightforward solution for most of the problems linked to air emissions from
ships; this would align shipping with other forms of transport based upon engine power
 large reduction of SOx, and PM emissions and significant further reduction of NOx and
CO2 emissions with no other investment than a higher price for the fuel
 distillate fuels do not contain significant quantities of absorbed nitrogen and thus any
extensive use of these would ensure an immediate and natural reduction of NOx emissions
in the region of 10 to 15% on existing levels under all power/load conditions.
 eliminates the need for bunker treatment plants currently onboard ships thereby avoiding
aspects of Regulation 18.1.a.iii.1, e.g. Catalytic Fines
 reduces the amount of generated fuel waste that needs to be stored, handled and treated
onboard;
 for ships using only a distillate fuel, a significant advantage would be a reduction in the
number of tanks and piping arrangements that would otherwise be required for diverse fuel
types and qualities requiring segregation.
 eliminates complex operations related to multi-fuel ships with the associated safety
implications, for example as would possibly arise during a change between three grades on
a voyage.
 enhances safety by avoiding potential problems related to human errors, particularly during
fuel quality changeovers.
 residuals fuels with low sulphur content, as the alternative to distillate fuels, require further
substantial onboard equipment to reduce PM emissions
2
 the use of distillate fuel only would mean that ships would use globally a single and well
defined type of fuel; and supporting legislation would simplify the monitoring and
regulatory control mechanisms for fuel quality compliance
 Use of distillate fuel as bunkers would result in an associated reduction of CO2 emissions
from ships.
 the use of distillate fuel would align fuel quality criteria for shipping with those for
virtually all other forms of transport, and.
 there would be no competitive advantage if all ships were to use the same type of fuel
6. If there were a desire to require only distillate fuels, Regulation 18 could be revised as
follows:
Revised Regulation 18.1 to read:
Fuel oil for combustion purposes delivered to and used onboard ships to which this Annex
applies shall be distillate fuels of a quality as defined in Appendix VI herewith and shall
meet the following requirements. . . . . .
7.
Oxides of Sulphur Emissions – Regulation 14 - When reviewing this Regulation in
general, some significant aspects must be taken into consideration concurrently. These are:
a) The emissions of Oxides of Sulphur (SOx) are a significant proportion of the total of
Particulate Matter (PM) generated by the combustion of fuels from ships. Any attempt
to limit the extent of PM emissions from ships would mean the installation of an
exhaust treatment plant or a requirement for betterment in the quality of fuel used by
ships that would include a reduction in the sulphur content of that fuel.
b) Any reduction in the regulated Sulphur content of the fuel used by ships would impact
all ships of differing ages and, thus, reference should be made to the sophistication of
technologies installed onboard capable of combusting such fuel without the necessity
to introduce significant modifications to the respective engines. Under the current
provisions of MARPOL Annex VI any existing engine subjected to “substantial
modifications” would need to meet the standards in the current Regulations.
c) In addition to the foregoing and with regard to the ability of refiners to reduce the
sulphur content of residual oils during the refining process, a complicated procedure is
utilised that would incur significantly increased requirements of energy to enable the
process to reach the desired results. This in turn would create increased amounts of
CO2 that the international community and IMO (on behalf of shipping) are attempting
to reduce.
8.
It is also necessary to consider the concept of Sulphur Emission Control Areas
(SECAs) and their relevance in the Regulation. The specific observations relating to these
areas are:
a) The current two SECAs identified within the Regulation are those of the Baltic Sea
and the combined English Channel/North Sea areas. These areas have defined
geographic limits specified by the Regulation. From an environmental point of view,
3
the concept of a SECA gives an emission control benefit for a small geographical area
notwithstanding that air pollution does not respect such “artificial boundaries” and
emissions outside of such artificial boundaries can still impact the sea area within the
boundary limits thereby reducing the net environmental effect sought by the
Regulation.
b) Each time a vessel has to enter this artificially defined area, a changeover routine has
to be completed before entry conditions in to the SECA are met. Such changeover
routines are undertaken approaching the boundary limits of the SECA which, at
present, are either close to inshore waters and/or have high shipping activity.
c) Although only two specified SECAs currently exist, it is known that work is currently
being undertaken to justify applications to IMO for additional SECAs elsewhere. Such
Sulphur demarcation zones will increase the demand for low sulphur fuel and add to
the safety implications associated with the fuel changeover procedures for entry into
these areas.
d) The risks involved with the creation of incompatibility between two fuels qualities as
a result of blending during the changeover process inducing loss of engine power by
blockage of filters are considered possible thereby raising the very real issue of vessel
safety.
e) Many existing and recently delivered ships are not equipped to handle multi-fuel
requirements and any proliferation of SECAs, especially if there is not a consistency
in standards, will compound the problems currently being encountered.
9. Based on the above, there would appear to be merit in expanding SECAs to a world
wide concept. If this was a desired outcome, Regulation 14 could be revised as follows:
(1)
Revised Regulation 14.1 to read:
The sulphur content of any fuel used on board ships shall not exceed 1.00 % m/m. Should
this requirement directly necessitate either a major conversion or substantial modification
to a vessel’s engine as referred to in Regulation 13.2 then vessels with engines built
before[1 January 2000]/[2010] need not comply with the requirements of Regulation 13.2.
(2)
Add a new paragraph 14.1 bis to read:
The sulphur content of any fuel used onboard ships whose engines are built after [2015]
shall not exceed 0.50% m/m.
(3)
Remove Regulations 14.3, 14.4 14.5, 14.6, and 14.7
10
Reasons: The reasons the above issue should be discussed further are summarized as
follows:

By stipulating a global Sulphur cap of 1.00% m/m in the first tier (tier II) reductions
and a possible requirement for new engines to use [0.50]% Sulphur fuels in [2015]
4


(tier III) should already cover the current provisions covered in regulations by SECA
concept. Consequently, the necessity for fuel changeover for entry into a SECA is
removed together with any resulting safety implication and with a clearly explained
environmental benefit of further SOx emissions reduction. This also has an
immediate advantage in a much simpler compliance monitoring system.
By stipulating the type of fuel to be used, e.g. distillate fuels, this could achieve a
better and cleaner combustion potentially satisfying the expected requirement for the
reduction in Particulate Matter in the exhaust gases.
With the sole use of distillate fuel, the necessity for additional tanks, piping systems,
fuel treatment systems is removed. However any engine modification allowing an
existing vessel engine to comply with the proposed requirement should be
recognised and relief or dispensation should be given for compliance with the
requirements in Regulation 13.2 (the NOx Regulations) given the NOx reduction
achieved by the fuel change.
11. Oxides of Nitrogen Emissions – Regulation 13 - NOx is not only an air pollutant of
itself but also a precursor to the generation of tropospheric ozone – a greenhouse gas as
recognised by the UNFCCC. Unlike other air emissions from ships, the production of this
gas is not primarily related to fuel quality but that relating to the functioning of the engine
and its combustion regime.
12.
Initial discussions on the issue of Regulatory amendment for this gas have intimated
an expectation for a two tier reduction from the existing regulatory levels: an additional 40%
from 2010 and a further tier III reduction by 2014 or 2015. From the best advice available
provided by engine manufacturers and with the current proven technology available, the 40%
further reduction by 2010 may require additional external (to the engine)
equipment/technology to achieve this target.
13.
It is important to note that the targeted reduction of NOx emissions is more important
in coastal zones and harbours. The onboard abatement technology, currently available, is
generally most efficient at full load of the ship’s engine but its efficiency drops significantly
when the engine load decreases as the ship slows down. Therefore, it is questionable whether
onboard abatement technology and/or modified turbo-charger would give any net positive
environmental effect, as desired of the Regulation, when the engine is on reduced load during
manoeuvring.
14.
The use of distillate fuels in any engine, including existing engines, would, however,
have an immediate benefit in reducing NOx of approximately 10% to 15% under all load
conditions.
15.
Reasons: The reasons the above issue should be discussed further are summarized as
follows:

The NOx Technical Code (paragraph 6.3.11) gives guidance as to the potential for
NOx reduction of between 10 and 15%, at least, by use of a cleaner distillate fuel that
would contain very much smaller quantities of nitrogen in its molecular structure.
Thus, a change in the fuel quality criteria is an immediate solution for a reduction of
NOx emissions from all ship’s engines under all engine running conditions.
5

The proposed tier or timed system for the reduction of NOx has merit, but it should
be decided only after a professional assessment as to whether the time given for the
development and required testing of equipment to meet the Regulatory objectives is
adequate.
Volatile Organic Compounds (VOC) – Regulation 15 - VOC gas is generated during
loading and during the transportation of volatile hydrocarbon cargoes such as crude oil and
gasoline on board tankers. The current Regulation 15 only applies when a port or a terminal
requires the control of release of this type of gas to the environment and only then is the
tanker required to have the ability to transfer the evolved gas from the cargo (vapour return
pipeline) back to a shore reception facility for the control of such emissions. The issue of
VOC control, as far as air pollution is concerned, may be co-related to NOx emissions in so
far as it is a precursor for the generation of stable tropospheric ozone – a recognised Green
House Gas.
16.
17.
A submission by Norway (ref. DOCUMENT – BLG 10/14/2) proposes that this
Regulation is modified such that it requires all tankers to have a VOC Management Plan
when loading and transporting volatile hydrocarbon cargoes. This “plan” should be simple to
operate and be an operational procedure that is compiled to suit an individual tanker’s ability
to undertake the procedure. The ISM manual contains guidance for many operational
procedures for tankers but there are other mandatory manuals on board a tanker such as the
Crude Oil Washing Manual that supplies guidance in order to perform this mandated task for
cargo tank cleaning. An example of such a procedure included in the Norwegian proposal is
that of the INTERTANKO VOCON procedure.
18.
INTERTANKO comments on VOC emissions:
1. The Norwegian proposal is supported in principle but INTERTANKO suggests that
the title to this plan be changed from “VOC Management Plan” to “VOC Operational
Control Procedure” that can be compiled and adopted to suit the individual procedures
and resources available for each tanker.
2. The selected procedure can either be included in the vessel’s ISM Manual or produced
as a separate manual – such as the Crude Oil Washing Manual – but in the latter event
guidelines will have to be generated by the Organisation as to its content and form.
3. A minimum vapour pressure will have to be selected by the Organisation as to when
such a procedure should be activated for a specific cargo and the proposal for such a
value would be a Reid Vapour Pressure of more than 6.0 psia or 41 kPa.
4. A maximum vapour pressure should be selected for all cargoes to be carried by a
tanker in order to control the extent of VOC emissions. A proposal for this value
would be a Reid Vapour Pressure of [10 psia or 70 kPa].
19.
Reasons: The reasons the above issue should be discussed further are summarized as
follows:
. The control of VOC emission is primarily an operation procedure undertaken onboard
either during loading or its subsequent transportation. Certain procedures adopted
utilise equipment and technology as installed onboard a tanker (e.g. the KVOC system
and procedure) whereas others rely upon the control of vapour pressures within the
cargo tank vapour system. Thus it is deemed more suitable to apply the term
“Operational Procedure” rather than a “Management Plan” given the individual
6


resources available to individual tankers and dependent upon the physical nature of
the oil which is to be supplied to the tanker by reference to the required Material
Safety Data Sheet (MSDS).
There are very many differing grades and qualities of crude oil with a wide variety of
concentrations of volatile components in the crude oil. Some crude oils have a high
Pour Point temperature characteristic necessitating cargo heating and a high
temperature environment causing a lot of the volatile components to have “boiled off”
prior to loading. Other types of oil have very limited gaseous content upon loading
whilst others are stabilised to varying degrees prior to loading. Thus, with regard to
the minimum vapour pressure requirement for the activation of a VOC Operational
Control Procedure, empirical research and data has shown that, for values less than the
pressure proposed by INTERTANKO, the extent of VOC emission is reduced with the
likelihood of releases during transportation to be minimal.
Onboard measurements and other relevant data have shown that, over the recent
decades, the volatility of crude oil has, in general, increased. Tankers, however, are
designed to load and transport cargoes of relatively low volatility with the more
volatile hydrocarbon types being designated for transportation on Gas carriers. In
order to avoid the consequences of loading and transporting cargoes of high volatility,
a maximum volatility criterion should be set for the volatility of acceptable cargoes
for loading and transportation on traditional tankers. The value proposed by
INTERTANKO is based on direct observations and measurements and would indicate
the demarcation/maximum Reid Vapour pressure of cargoes to be offered for
transportation at sea. That would imply pre-treatment of cargo prior to loading but in
return will assist in avoiding excessive VOC emissions and improve the safe
transportation of the cargo.
20.
Particulate Matter (PM) - As a result of submissions regarding the revision of the
Regulations in the current version of Annex VI proposals have been put forward to control
the emissions of Particulate Matter in the exhaust gas stream from the engines onboard a ship.
Particulate matter in engine exhausts consists of a mixture of particles of differing types and
sizes. Primarily these particles are mainly of micron size with a criteria selection for any
Regulation of either 2.5 micron or 10 micron.
21.
The particles consist of:





Sulphates – oxidised Sulphur Dioxide from the combustion process of fuels
containing sulphur
Nitrates – oxidised Oxides of Nitrogen from the combustion process
Uncombusted hydrocarbons - stemming from the quality of fuel oil and the efficiency
of the combustion process
Soot – carbonised hydrocarbon from the combustion of certain components in residual
fuels
Heavy Metals – such as, but not limited to, Aluminium, Silica, Vanadium, Nickel and
Iron – all these elements are to be found in residual fuel oils in differing
concentrations and quantity
22.
Given that these particles are all in the form of (near) solids then additional onboard
technology would be needed to remove these particles from the exhaust gas stream. At
7
present, the requirements and definitions for any proposed Regulation are not yet agreed, nor
the limiting control. With this in mind, the technology required for the removal of any defined
particulate matter that would meet the demands of any Regulation have yet to be developed.
If such a Regulation is constructed for particulate matter then it is possible that it would
come into force on the proposed date for the totality of the revision in 2010. A simple and
immediate solution to a significant reduction of PM would be the use of distillate fuels only.
23.
Reasons: The reasons the above issue should be further discussed are summarized as
follows:



By changing the fuel type to a distillate then the production of PM will be
significantly reduced. Distillate fuels such as Marine Diesel Oil are capable of being
produced with lower sulphur content; with better combustion properties thereby
reducing both the extent of uncombusted hydrocarbons and soot; extremely low heavy
metal content; and considerably lower nitrogen content.
The use of a fuel compliant with a specification could be included in MARPOL
Annex VI (such as shown in the proposed Appendix VI attached to this paper and
which is similar to the ISO 8217 DMB Specification) which could result in a 98%
reduction in carbon residues and a 93% reduction in ash content as a result of the
fuel’s combustion
Changing the fuel quality to a marine distillate and creating less Particulate Matter
may lessen the need for regulatory controls and requirements for this type of emission,
thereby avoiding the necessity for fitting of emission control technology and the
storage onboard of diverse Particulate Matter as itemised above for subsequent
disposal ashore.
24. Fuel Specification for proposed Appendix VI to Annex VI – INTERTANKO believes
that in order to strictly regulate emissions from ships, MARPOL Annex VI should include a
Fuel Specification. INTERTANKO has made reference to and introduced the concept of a
Fuel Standard in paragraph 6 above, regarding a possible Amendment to Regulation 18.1.
The Fuel Specification should be added to MARPOL Annex VI as Appendix VI. As referred
to in paragraph 6 above regarding a possible amendment to Regulation 18.1, a Fuel Standard
is given on the last page of this document.
26.
Reasons: The reasons for further discussion of the above issue are summarized as
follows:


Given that the fuel specification is probably the most important element for emissions
control, it seems advisable the Organisation develops its own Marine Fuel Standard
even though this might be close to the standard given in ISO 8217.
The fuel standard proposed is adopted from the current ISO 8217 standard for
distillate grade fuels and can thereafter be updated by the Organisation as the
regulatory body when deemed necessary.
Monitoring and checking compliance
27. INTERTANKO has no specific comments to amend the current provisions for
monitoring and checking compliance of the provisions in Regulations 14 and 18 at this time
for two basic reasons: (1) such amendments would be under the purview of the MEPC or
8
BLG and (2) the formulation of possible changes need to be addressed after the intersessional
working group have had a chance to discuss our proposals for amendments presented on this
paper. Pending future developments, INTERTANKO will submit specific proposals on this
matter to the next sessions of either MEPC or BLG as appropriate..
Conclusions
28.. INTERTANKO outlines a number of issues that merit further discussion that would
assist the working group to find an efficient and simple approach for revision of MARPOL
Annex VI and a significant reduction of exhaust emissions. The issues put forward are
reviewed mainly from an environmental perspective and do not take into account additional
features where positive operational advancement or gains can be achieved. From an
operational perspective, the proposals provide simplicity in operations and allow for further
investigations for optimising fuel consumption by energy maximisation and an associated
reduction in air emissions.
Action requested of the Working Group on Air Pollution
29.
The Intersessional Working Group is invited to further discuss the issues raised in this
paper in its consideration of the revision of MARPOL Annex VI and the NOx Technical
Code and take action as appropriate.
9
Appendix VI (similar to ISO 8217: DMB)
Quality Specification for Marine Fuel Oil
For the purposes of application to Regulation 18.1 the following specification will apply to
all Marine Fuel Oil supplied to ships
Characteristic
Unit
Limit
Specification
kg/m3
mm2/s
o
C
o
C
% m/m
% m/m
% m/m
max
max
min
max
max
min
max
max
Total Sediment, existent % m/m
Water
% v/v
max
max
900.0
11.0
60
0
1.00
40
0.30
0.01
Clear and
Bright
0.10
0.3
Density at 15 o C
Viscosity at 40 o C
Flash Point
Pour Point (upper)
Sulphur
Cetane Index
Carbon Residue
Ash
Appearance
Test Method
Reference
ISO 12185
ISO 3104
ISO 2719
ISO 3016
ISO 8754
ISO 4264
ISO 10370
ISO 6245
Visual inspection
ISO 10307-1
ISO 3733
The values recorded for each individual parameter are considered a maximum or minimum,
as appropriate, and thus any value found outside of the stipulated limits by testing in
accordance with the reference test method procedure i is deemed not to comply with the
requirements of Regulation 18.
The fuel will not contain any detectable concentrations of metals, by use of the reference test
method IP 501, that could damage the engine or adversely impact the exhaust from the
engine under combustion of the fuel.
Upon visual inspection, if the sample of the fuel, taken in compliance with the guidelines for
the sampling procedure, is found to be “clear and bright” then it will be deemed to also
satisfy the specification limit parameters for water concentration and total sediment existent.
i
Reference to the reference test method procedure specifically excludes reference to the relevant procedures
repeatability and reproducibility limits
10