MARPOL Annex VI Regulations for the Prevention of Air Pollution from Ships Dragos Rauta INTERTANKO INTERTANKO NORTH AME

1. MARPOL Annex VI Regulations for the Prevention of Air Pollution from Ships Dragos Rauta INTERTANKO INTERTANKO NORTH AMERICAN PANEL October 4th, 2005 Houston, TX

2. Ratified by 22 Governments that have a combined tonnage over 50% of World tonnage ENTERED INTO FORCE on MAY 19th, 2005 Ratification by: Azerbaijan, Bahamas, Bangladesh, Barbados, Bulgaria, Cyprus, Denmark, Finland, Germany, Greece, Japan, Liberia, Marshall Islands, Norway, Panama, St. Kitts and Nevis, Samoa, Singapore, Spain, Sweden, United Kingdom, Vanuatu. RATIFICATION

3. All Ships are to comply irrespective of Flag State – Article 5(4) of MARPOL Convention – “no more favourable treatment” But no obligation for ”non party” Governments Many major ports still ”non-parties” (e.g USA, The Netherlands, etc.) Bunkering in a “non party” port followed by a call in a “party” port – source of trouble out of ship’s control Bunker Delivery documentation and Sample – here is the difficulty – FSI 13 & MEPC 53 IMPLEMENTATIONMission impossible?

4. Certification application: any ship of 400 GT and above New ships – before enter into service (built on or after 05/19/2005) Existing ships – not later that the first scheduled dry-docking but not later than 05/18/2008 Survey Intial Periodical (5 years) Intermediate Annual Certification & Survey under Annex VI

6. Scope: Control of exhaust gas emissions from ships Regulations for limiting/eliminating emissions of: Ozon-depleting substances Nitrogen oxides (NOx) Sulphur oxides (SOx) Volatile organic compunds (VOC) Shipboard incinerators Additinal requirements for: Reception facilities Fuel oil quality MARPOL Annex VI

7. Any deliberate emissions shall be prohibited New installation containing HCFCs (hydrochlorofluorocarbons)are permitted until January 1st, 2020 These substances, when removed from ships, must be delivered to reception facilities Ozone-depleting substances

8. New engines (i.e. power > 130 kW, installed on ships with buildng contract as from 01/01/2000) need to be compliant The NOx emission is limited to 17 g/kW h for engines operating at max. 130 rpm but reducing to 9.8 g/kW h for 2000 rpm and more. Between these revs the limit is designated by equation: 45 * n(-0.2) g/kW h Existing engines can be run, but Major Conversion: engine replacement after January 1st, 2000 substantial modification as defines in the NOx Tech. Code the MCR of the engine is increased by more than 10% Nitrogen Oxides (NOx)

9. Identification of components, settings and operating values which influences NOx Identification of the full range of allowable adjustments of alternatives for the components Full records of the engine’s peformance Onboard NOx verification method Technical File

10. Sulphur content of bunkers should not exceed World wide trade 4.5% Baltic Sea (from 05/19/2006) 1.5% North Sea (from 10/2007 or 08/2007) 1.5% Alternative exhaust gas cleaning on: funnel IG scrubbers Sulphur Oxides (SOx)

11. Plan in advance for entry and enter commencement date/time of preparation in Logbook together with bunker type quantities onboard. Logbook record when entry requirements met and when ship enters SECA - remember Lat. & Long., date/time, together with bunker figures for each tank. Maintain daily record of bunker used and quantification of bunker tanks whilst in SECA. DO NOT COMMENCE SHIFT TO HIGH SULPHUR FUEL UNTIL EXIT FROM SECA. Log existing conditions for bunkers and Lat. & Long. with date/time. Shipboard Procedures for SECAs

12. ALTERNATIVES for SECAs

13. Specific control of VOC emissons in ports and terminals Tankers to have and use vapour collection systems (return lines) at the loading ports (VOC return manifold and operation standards in MSC/Circ.585) Ports/terminals to provide reception facilities for VOCs So far, very few terminals have such facilities New technologies Volatile Organic Compounds (VOC)

14. Incinerators installed after Jan. 1st, 2000 to meet regulations and must be certified to meet the specifications in MEPC Resolution 76(40) (Appendix IV of Annex VI). Each incinerator must have a manufacturer’s operations manual. Crew responsible for the incinerator operation shall be trained and follow the operation manual. Incinerators

15. The following substances are prohibited from incineration: Annex I, II and III cargo residues and related packing material. PCBs. Garbage as defined by Annex V containing heavy metals. Petroleum Products containing halogens. PVC can only be incinerated in type approved incinerators. Flue gas temperatures shall be monitored and not less than 850 deg C for continuous feed and reach 600 deg C within 5 minutes for batch feed. Operation of Incinerators

16. “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, or is harmful to personnel, or contributes overall to additional air pollution” Fuel Oil Quality

17. Bunker Delivery Note (BDN) Becomes a Statutory document Must be kept on board for 3 years for inspection and a copy may be taken for further examination by PSC. Must contain all data required by Appendix V Name and IMO number of vessel Port Date of Commencement of delivery Details of fuel oil supplier Product name, quantity , Density at 15 0C and Sulphur content % m/m A declaration that fuel supplied meets Regulation 14 and 18 requirements Fuel Oil Quality

19. bunker suppliers should make the certification in the BDN in the column provided for supplier’s confirmation, as follows: “We certify that the bunker fuel oil delivered meets the requirements of regulations 14 and 18 of Annex VI of MARPOL 73/78.” Declaration on Fuel Oil Quality

20. A sealed sample meeting the requirements in associated guidelines has to be supplied to the ship by the bunker supplier For each individual BDN a sample has to be taken at the vessel’s bunker receiving manifold. (see procedure in associated guidelines) – ISM Manuals !!?? 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 mls The sample is not to be used for any commercial purpose The sample is to be retained on board for at least 1 year for inspection by PSC as required Fuel Oil Quality - Sampling

21. Adequate bunker manifold location for sampler attachment External safe storage location for samples for 1 year period Log book for sample retention and custody transfer Safe storage for BDNs and other documents relating to bunkering onboard Shipboard Procedures for BDN and Samples

22. Owners warrant that the vessel shall comply with the emission control and other requirements of Regulations 14 and 18 of MARPOL Annex VI and any other laws or regulations relating to bunker specification and bunkering procedures applicable in any areas to which the vessel is ordered. Charterers warrant that they will supply bunkers: of sufficient quantity and quality to enable the vessel to meet the emission control and other requirements of Regulations 14 and 18 of MARPOL Annex VI and any other laws or regulations relating to bunker specification and bunkering procedures applicable in any areas to which the vessel is ordered, and in accordance with the specifications in the latest version of ISO 8217 as at the time of supply and any other specifications contained elsewhere in this charter party. Charterers further warrant that all bunker suppliers shall comply with the requirements of MARPOL Annex VI and MEPC96(47) in respect of sampling and the provision of a bunker delivery notes and, where bunkers are supplied in a state where MARPOL Annex VI is in force, that suppliers shall be registered in accordance therewith. Bunker Emission Clause for time charters

23. IMO Guidelines for PSCO adopted at MEPC53 Initial inspections and Primary survey parameters – then “Clear Grounds” required for in-depth inspections “In depth” inspection parameters Detainable deficiencies Non-Party ship inspections Port State Control

24. EIAPP Cert. And Technical File for each D/E Record of Engine Parameters Manual for onboard direct measurement and monitoring (if applicable) Official Log Book Operation manual of Vapour collection system Operation manual for Incinerator Bunker Delivery Note - Ship’s Note to Flag States – reports on non-compliance Onboard certificates & documentation

26. ANNEX VI OF MARPOL - REGULATIONS NOx Emissions; Regulation 13 SOx Emissions; Regulation 14 Fuel Quality requirements - Regulation 18 The Bunker Delivery Note (BDN) Bunker Sampling Procedure and Method to comply with Regulation 18 The Bunker Manifold Construction and Location Prescribed sampling methods or system Method for sub-sampling for Retention sample Retention Sample Storage NECESSARY ALTERATIONS TO MEET ANNEX VI REQUIREMENTS Pre-bunkering meeting and check list Sampling and Measurement procedures Post-bunkering documentation process INTERTANKO Guide to bunkering of ships for the purposes of Annex VI to MARPOL, June 2004

27. MEPC 53 – July 2005 decided to open Annex VI for revision Possible revisions on: World and SECA sulphur cap New SECAs Lower NOx limits Possible new requirements: Include limits for PM Require specific technologies to contain VOCs MARPOL Annex VIfuture developments/amendments

28. EU Sulphur Directive 2000 – if used, MGO/MDO max. 0.2% sulphur content 2010 – as Annex VI + use of 0.1% sulphur content fuels for ships ”at berth” EU to promote its policies to IMO but will go its way if IMO too slow or not receptive to new proposals USA Federal - EPA State legislations Regional Requirements