MARPOL Annex VI Chapter 1-3: “Air Pollution and GHG Emissions from International Shipping”

1. MARPOL Annex VI – Chapter 1-3:
“Air Pollution and GHG Emissions
from International Shipping”
Mohammud Hanif Dewan, IEng IMarEng MIMarEST MRINA
Maritime Lecturer & Consultant

2. Introduction
MARPOL Annex VI:
Prevention of Air Pollution from Ships

3. Energy use is the major source of man-made air emissions
Air emissions from combustion of fuels

4.  Consequences:
 Damage to environment and eco-system
 Damage to agriculture and properties.
 Damage to human health.
 Additional cost to society and individuals (healthcare, accidents,
etc.)
 Solutions (mitigation aspects):
 Either to reduce the air emissions (Technical and operational
measures); OR
 Pay for the associatedcosts (market based measures); OR
 A combination of the above two
 Mechanisms:
 Regulations (on technical and operational measures)
 Market-BasedMeasures(MBM)
Overall consequence and solutions

5. MARPOL Annex VI Overview

6. MARPOL Annex VI – Regulations for the Prevention of
Air Pollution from Ships
 MARPOL Annex VI:
 1997 Protocol adopted 26 Sept. 1997
 Entered into force 19 May 2005
 Revisions to Annex VI
 Adopted October 2008 and
 Entered into force 1 July 2010
 Chapter 4 on Energy Efficiency
 Adopted in 11 July 2011
 Entered into force 1 January 2013
Some changes to text or guidelines took place in
almost all MEPC meetings.

7. • Sulphur Oxides or SOx: come from
burning the sulphur present in fuel
oils. Corrosive and harmful to life.
• Particulate matter (PM) or soot:
consists of unburned fuel or
incombustible elements in the fuel.
Highly carcinogenic. The very small
or ultrafine particles are the most
harmful ones.
Nitrogen Oxides (NOx): are produced when engines heat up the
Nitrogen and Oxygen in air. Highly toxic and dangerous form of
pollution.
Carbon Dioxide (CO2 ): is an inevitable product when we get energy
from burning the carbon in fuel. Responsible for global warming and
climate change. Directly proportional to the amount of energy released.
Marine Exhaust Gas Pollution

8.  Carbon Monoxide (CO)
 Carbon Dioxide (CO2)
 Sulphur Oxides (SOx)
 Nitrogen Oxides (NOx)
 Unburned Hydrocarbons
(HxCx).
 Particulate Matters (PM)
Source: MAN B&W
Emission Gases from Engine Exhaust

9. Regulationsfor the followingemissions
Energy
Efficiency
NEW
MARPOL Annex VI

10. Chapter 1 – General
 Reg. 1: Applications
 Reg. 2: Definitions
 Reg. 3: Exceptions and exemptions
 Reg. 4: Equivalents
MARPOL Annex VI – Regulations

11. MARPOL Annex VI – Regulations
Chapter 2-Survey, Certification and Means of Control
 Reg. 5: Survey and inspectionsReg.5
 Reg. 6: Issue of endorsement of certificate
 Reg. 7: Issue of a certificate by another party
 Reg. 8: Form of certificate
 Reg. 9: Duration and validity of certificate
 Reg. 10: Port state control and operational
requirements
 Reg. 11: Detection of violation and enforcement

12. MARPOL Annex VI – Regulations
Chapter 3 - Requirements for Control of Emissions
Reg. 12: Ozone displacing substances (ODS)
Reg. 13: Nitrogen oxides (NOx)
Reg. 14: Sulphur oxides (SOx)and Particulate Matter (PM)
Reg. 15: Volatile organic compounds (VOC)
Reg. 16: Shipboard incineration
Reg. 17: Reception Facilities
Reg. 18: Fuel oil quality and availability

13. MARPOL Annex VI – Regulations
 Reg. 19: Application
 Reg. 20: Attained EEDI
 Reg. 21: Required EEDI
 Reg. 22: SEEMP
 Reg. 23: Technical cooperation and technology transfer
Chapter 4 - Energy Efficiency Regulations

14. MARPOL Annex VI – Regulations
• Reg. 24: Application of III Code
• Reg. 25: Verification of compliance to III Code
Chapter 5 -Verification of compliance
(within IMO Member States Audit Scheme)
III Code refers to the IMO Instruments Implementation Code
adopted by the Organization by resolution A.1070(28).

15. Survey and certification summary
Surveys and Certification
• All ships of ≥ 400 gross tonnage
Subject to Initial,
Periodic (renewal) and
Intermediatesurveys
International Air
Pollution Prevention
(IAPP) Certificate
• Ships constructedbefore date of
entry into force of Annex VI for non-
Parties.
• Comply by 1st scheduled dry-dock
but no later than 3 years after
entry into force.
•Fixed or floating platforms (drilling
rigs)
• Floating craft and submersibles

16. MARPOL Annex VI - Chapter 3 Regs
Requirements for Control of Emissions from Ships

17. MARPOL Annex VI – Regulation 12
Ozone Depleting Substances (ODS)
Emissions from ODS from refrigerating plants
and fire fighting equipment.

18. R11
ODP = 1.0
GWP = 4000
R12
ODP = 0.9
GWP = 8500
R115
(R502)
ODP = 0.283
GWP = 5591
CFC
Chlorofluorocarbon
Production Ban 1996
Article 5 countries 2010
R22
ODP = 0.055
GWP = 1700
R141b
(Foam blow)
ODP = 0.11
GWP = 630
HCFC
Hydrochlorofluorocarbon
Transitional Substance
Banned in new plant
R410A
ODP = 0
GWP = 1890
(High Pressure)
R404A
ODP = 0
GWP = 3748
(High GWP)
R507
ODP = 0
GWP = 3800
(High GWP)
R407C
ODP = 0
GWP = 1610
(Flammability?)
HFC
Hydrofluorocarbon
Ozone Friendly
Under question
Ammonia
ODP = 0
GWP = <1
Carbon
Dioxide
ODP = 0
GWP = 1.0
Propane/
Isobutane
ODP = 0
GWP = 3.0
Environmentally
Inert
Natural Substances
Refrigerants - Family Tree, ODP, GWP
ODP – Ozone Depleting Potential
GWP – Global Warming Potential
19 May 2005
01 Jan 2020

19. Regulation 12 - ODS
 Does not apply to permanently sealed units (Reg.12.1)with no
charging connection …
 Deliberate emissions prohibited (Reg.12.2)
 Other than Hydrochloroflurocarbon (HCFC) & Hydroflurocarbon
(HFC), all other ODS (Like CFC) banned in new ships from 19
May 2005 (Reg.12.3.1)
 HCFC banned in new ships from 1 Jan 2020 (Reg.12.3.2)
 Delivery to reception facilities following removal (Reg.12.4)
 Supplement to IAPP - Maintain a list of equipment containing ODS
(Reg.12.5)
 Required to complete an ODS Record Book approved by
Administration (Reg. 12.6) for ships with re-chargeable systems.

20. Regulation 12 – Entries in ODS Record Book
 Regulation 12.7: Entries in the ODS Record Book shall be
recorded in terms of mass (kg) of substanceand shall be
completed without delay on each occasion:
 .1 recharge, full or partial, of equipment containing ODS;
 .2 repair or maintenance of equipment containing ODS;
 .3 discharge of ODS to the atmosphere including deliberate;
and non-deliberate;
 .4 discharge of ODS to land-based receptionfacilities; and
 .5 supply of ODS to the ship.

21. MARPOL Annex VI – Regulation 13
Prevention of Nitrogen Oxides (Nox) emissions

22.  NOx is a reactive gas, at the presence of sunlight.
 Causes health problem; in particular on respiratory
system.
 NOx together with VOC and other reacting gases
could lead to smog (smoky fog) phenomenon.
 Additionally, NOx contributesto global warming and
acid rain.
Photochemical smog is the chemical reaction of sunlight, nitrogen oxides
and VOC in the atmosphere, which leaves airborne particles and ground-
level ozone
Impact of NOx

23.  There are a number of NOx reduction methods for engines.
LNG
NOx
Reduction
Options
Others
EGR
SCR
 Water in fuel
emulsions.
 Humid Air Manifold or
water injection.
 Miller cycle: Valve
timing.
 Low NOx
combustion.
 Lean burn, low
temperature
combustion.
 Low combustion
temperature due to
gas recirculation
(mainly CO2)
 Use of a
reduction agents
 Uses a catalyst
Converts NOx back
to N2
Methods of engine's NOx reduction

24. Regulation 13 NOx - Application
Applies to
installed on a ship
constructed on or after
1st January 2000
Marine
diesel
engines
with a power
output more
than 130 kW
Applies to
which undergo a major
conversion on or after
1st January 2000
Marine
diesel
engines
with a power
output more
than 130 kW
Not applicable to
• Emergency marine diesel engines
• Marine diesel engines installed on lifeboats
• Any device or equipment intended to be used
solely in case of emergency
• Engines on ships only engaged in domestic
voyages can be made subject to alternative NOx
control measure or exempted if pre-19 May 2005

25. Regulation 13 -NOx emission limits
• NOx emission limits
Tier I * - Ships constructed 1 Jan 2000 to 31 Dec 2010
Tier II - Ships constructed 1 Jan 2011 to 31 Dec 2015
Tier III ** - Ships constructed 1 Jan 2016 onwards
*NOx limit in original Annex VI ** Within ECA
Tier n < 130 rpm 130 ≤ n < 2000 rpm n ≥ 2000 rpm
I 17.0 g/kWh 45.0*n(-0.2) g/kWh 9.8 g/kWh
II 14.4 g/kWh 44.0*n(-0.2) g/kWh 7.7 g/kWh
III 3.4. g/kWh 9.0*n(-0.2) g/kWh 2.0 g/kWh
n = rated engine speed – crankshaft rpm

26. Regulation 13 -NOx emission limits

27. Regulation 13 (NOX) – Engine certification
 Test bed exhaust emission measurement by Engine Maker.
 NOx Technical File
• Information on components,settings, operating values & adjustments
to maintain NOx emissions within allowable limits.
 Issue of Engine International Air Pollution Prevention (EIAPP)
certificate or statement of compliance
• Issued for applicable engines
• Valid for the engines life time (unless major conversion)

28.  The NOx-influencing components and settings (depend on the design
of the particular engine) shall be listed in the engine’s Technical File:
1. Injection timing
2. Injection system components (nozzle, injector, fuel pump)
3. Software no, checksums, or other identification of software version
4. Hardware for fuel injection control
5. Camshaft components (fuel cam, inlet- and exhaust cam)
6. Valve timing
7. Combustion chamber (piston, cylinder head, cylinder liner)
8. Compression ratio (connecting rod, piston rod, shim, gaskets)
9. Turbocharger type and build (internal components)
10. Charge air cooler/charge air pre-heater
11. Auxiliary blower
The actual Technical File of an engine may include less components
and/or parameters other than the list above, depending on the
particular engine and the specific engine design.
NOx-influencing components

29.  Tier III – For ships built after January 1, 2016 when operating in North
America ECA.
 Applicable ships for future ECA-Nox:
 “for ships constructedon or after the date of adoption of such an
ECA-NOx, or a later date as specified in the adoption decision …”
 For meeting stringent Tier III NOx emission limits, NOx reduction
devices are expected to be used.
 If engines certified only to Tier II, can use NOx reduction device in
ECA. (Selective Catalytic Reduction (SCR) system is one such
device).
Regulation 13 - Tier III in ECA

30. MARPOL Annex VI – Regulation 14
Sulphur Oxides (SOx) & Particulate Matter (PM)

31.  SOx is normally SO2 and to some extent SO3.
 SOx is produced from oxidation of fuel sulphur
 S+O2 SO2 +1/2O2 SO3
 SOx causes: (1) Acid rain (2) Sea and soil acidification
and (3) Human health issue
 PM (Particulate Mater)is produced due to non-
complete combustionof fuel.
 Level of PM is dependent on fuel sulphur level.
 Reduction of fuel sulphur will reduce SOx but also PM.
How SOx is produced and what is its impact?

32. * depending on the outcome of a review, to be concluded in 2018, as to the
availability of the required fuel oil, this date could be deferred to
1 January 2025.
Exhaust gas cleaners/EmissionAbatement Technologies Permitted World wide
and in ECA under Reg.4 – Equivalents (Equivalence option limited to Parties)
Outside an ECA established
to limit SOx and particulate
matter emissions
Inside an ECA established to
limit SOx and particulate
matter emissions
4.50% m/m prior to 1
January 2012
1.50% m/m prior to 1 July
2010
3.50% m/m on and after 1
January 2012
1.00% m/m on and after 1
July 2010
0.50% m/m on and after 1
January 2020*
0.10% m/m on and after 1
January 2015
Regulation 14 Fuel sulphur limits

33. ECANon-ECA
1.7.2010
1.1.2015
4.50
3.50
1.50
1.00
0.10
0.50
1.1.2012
1.1.2020 1.1.2025
Fuel oil
% sulphur Review completion
by 2018
Time
Regulation 14 Fuel sulphur limits

34. Emission Control Areas (ECAs)

35. Sulphur Emission Control Areas (SECA) and Emission Control
Areas (ECA):
Adoption, entry into force & date of taking effect of Special Areas
SpecialAreas Adopted # Date of Entry into Force In EffectFrom
Annex VI: Preventionof air pollution by ships (Emission ControlAreas)
Baltic Sea (SOx) 26 Sept1997 19 May 2005 19 May 2006
North Sea (SOx) 22 Jul 2005 22 Nov 2006 22 Nov 2007
North AmericanECA
(SOx and PM)
26 Mar 2010 1 Aug 2011 1 Aug 2012
(NOx) 26 Mar 2010 1 Aug 2011 ***
United States
Caribbean Sea
ECA (SOx and PM)
26 Jul 2011 1 Jan 2013 1 Jan 2014
(NOx) 26 Jul 2011 1 Jan 2013 *** (01 Jan 2016)
(01 Jan 2016)

36. ECA Operation – Compliance and fuel change over
procedures
 Dominant option: Use of 2 separate fuels on-board, i.e. LS and HS
fuel oils.
 For this compliance option (Reg. 14.6):
 Ships entering or leaving an ECA shall carry a written procedure
(e.g. fuel change-over plan).
 The plan should show how the fuel oil change-over is to be done
ensuring not any HS fuel is left in the system upon entry into
ECA.
 The volume of LS fuel oils in each tank as well as the date, time,
and position of the ship when entering or leaving shall be
recorded in such log-book as prescribedby the Administration.
 Other options: LNG as fuel, Sox scrubbers,other alternative
fuels,

37. HSFO to LSFO Fuel Change-over Arrangement

38. HSFO to LSFO Fuel Change-over Calculator

39. Scrubber technology: How does it work?
 SOx is removed via
using wash water.
 System includes:
 Water supply
 Water treatment
 Exhaust gas and
water monitoring
 Supply to ship of
treatment agent.
 Types
 Fresh water
 Sea water
 Hybrid Source: Force Technology , 2012
See: http://www.youtube.com/watch?v=J8_D7ASh0_g

40. MARPOL Annex VI – Regulation 15
Volatile Organic Compounds

41.  Volatile Organic Compounds (VOCs) are the lighter parts of crude
oil or their products that vapourise during the ship loading process.
 VOCs are chemicals that are primarily dangerous to human health.
They also cause harm to the environment.
 VOCs are typically not very toxic, but instead have long-term health
effects.
 VOCs in shipping:
 Mainly from oil tankers.
 Normally polluting the port of loading.
 VOC could be discharged as part of tank purging process as
well.
What is VOC and its impact?

42. Regulation 15 - VOC
 Regulation enables ports and terminals to
implement VOC controls
 Controls on volatile emissions from tanker
cargo tanks during loading/ unloading of
oil cargoes
 Vapour Emissions Control System (VECS)
to be compliant with MSC/Circ.585
guidelines
 Crude oil tankers to have an approved
VOC manual (does not apply to gas
carriers - Reg. 15.7 )

43. Regulation 15 - VOC
 For Parties applying Regulation 15 in port(s) and terminal(s):
 Shall submit notification to IMO 6 months before effective date (Reg.15.2)
 Shall take into account IMO safety standards for VECS (MSC/Circ.585)
(Reg.15.5)
 IMO shall circulate list of ports and terminals (Reg.15.4)
 Tankers need to install a VECS approved by Administration (Reg.15.5)
 Ports/terminals with approved VECS can accept tankers without VECS for up to
3 years after effective date (Reg.15.5)
 Tankers need to develop and implement a VOC Management Plan approved by
the Administration (Reg.15.6)
 Procedures for minimizing VOC emissions during loading, sea passage &
discharge, responsible person identified, language, additional VOC during
washing
 Regulation applies to gas carriers for retention of non-methane VOCs (Reg.15.7)
but gas carriers not required to develop and implement a VOC management
plan.

44. MARPOL Annex VI – Regulation 16
Shipboard Incineration

45. Requirements:
- For Annex-VI compliance, the combustion
chamber temperature should reach 600ºC within
5 minutes of start-up
- All Incinerators should have a combustion
flue gas outlettemperature monitoring system
Regulation 16 - ship incinerators
 All Incinerators installed after 01 Jan 2000 shall be Type Approved,
as per IMO Specification for shipboard incinerators.
 Incinerators installed before 24 May 2005 on domestic shipping can
be excluded by the Administration (Reg. 16.6.2)
 Operating manual, training, and temperature control (Reg. 16.7 –
16.9)

46. Shipboard incineration - Regulation 16
 Prohibits incineration of
(Reg.16.2):
 MARPOL Annex I, II &
III cargoes,
 Polychlorinated
biphenyls (PCB),
 garbage containing
heavy metals,
 refined petroleum
products containing
halogens,
 exhaust gas cleaning
system residues
 Permits incineration of:
 PVC –(where type approved
to do so) (Reg.16.3)
 Sewage sludge and sludge
oil permitted in boilers but not
when in ports, harbours and
estuaries (Reg.16.)
 Incineration outside (in
drums, etc) prohibited

47. MARPOL Annex VI – Regulation 16
Reception Facilities

48. Regulation 17 – Reception Facilities
 Parties obliged to provide facilities without causing delay for:
 Reception of ODS in ship repair yards or ports
(Reg.17.1.1)
 Reception of Exhaust Gas Cleaning System residues in
ports (Reg.17.1.2)
 Reception of ODS in ship breaking facilities
(Reg.17.1.3)
 If unable to provide reception facilities then Party shall
inform IMO (Reg.17.2 & 17.3)

49. MARPOL Annex VI – Regulation 16
Fuel oil availability

50.  Parties to promote availability of compliant fuel oils and inform IMO
(Reg.18.1)
 Ship found not to be in compliance (Reg.18.2.1)
– Record of actions taken to achieve compliance
– Need to demonstrate “best efforts” to obtain compliant fuel
 Ship should not be required to deviate or delay unduly the voyage in
order to achieve compliance (Reg.18.2.2)
 Party required to take into account all relevant circumstances to
determine action (Reg.18.2.3)
 Ship required to notify Administration and port of destination when
unable to purchase compliant fuel (Reg.18.2.4)
 Party to notify when ship presents evidence of non-availability
(Reg.18.2.5)
Fuel Oil Availability – Regulation 18

51.  Required properties of fuel oil identified (Reg.18.3).
 Excludes coal, nuclear and gas fuels from some of the provisions (Reg.
18.4).
 When bunkering fuel oil …. It is required to receive a Bunker Delivery Note
(BDN) containing information in Appendix V (Reg. 18.5).
 BDN required to be retained for 3 years and be available for
inspection (Reg. 18.6)
 BDN accompanied by representative sample, taken in accordance to
MEPC.96(47), which is retained under the ship’s control for 12 months
(Reg.18.8.1).
 Verification of bunker sample to be done in accordance with Appendix VI
(Reg.18.8.2)
 Inspection and verification by PSC (Reg.18.7.1 & Reg.18.7.2).
Fuel oil quality – Regulation 18

52.  BDN to include the following information:
 Name and IMO number of receiving ship
 Port and Date of commencement of delivery
 Name, address and telephone number of fuel supplier
 Product name and Quantity
 Density
 Sulphur content (actual)
 Declaration signed by supplier that the fuel oil conforms with
Annex VI Regulations.
Bunker Delivery Note - Regulation 18

53.  Parties are required to:
 Maintain a register of local suppliers of fuel oil
(Reg.18.9.1)
 Require local suppliers of fuel oil to provide a certified
BDN and sample (Reg.18.9.2), and retain a copy of the
BDN for 3 years (Reg.18.9.3)
 Take action against local suppliers of fuel oil (Reg.18.9.4)
 Inform the Administration of a ship when the ship is found
to be non-compliant (Reg.18.9.5)
 Inform the IMO of all cases of non-compliant fuel oil
being supplied (Reg.18.9.6)
Local suppliers of fuel oil

54. Thank you for your attention
ANY QUESTIONS?
For more information please see:
www.imo.org