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IBIA ANNUAL CONVENTION SEPTEMBER 11, 2007. REDUCING AIR EMISSIONS FROM SHIPS JOSEPH ANGELO DIRECTOR, REGULATORY AFFAIRS AND THE AMERICAS. INTERTANKO. INTERNATIONAL ASSOCIATION OF INDEPENDENT TANKER OWNERS MEMBERSHIP 260+ MEMBERS 2,650+ TANKERS 220+ MILLION DWT
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IBIA ANNUAL CONVENTIONSEPTEMBER 11, 2007 REDUCING AIR EMISSIONS FROM SHIPS JOSEPH ANGELO DIRECTOR, REGULATORY AFFAIRS AND THE AMERICAS
INTERTANKO INTERNATIONAL ASSOCIATION OF INDEPENDENT TANKER OWNERS MEMBERSHIP • 260+ MEMBERS • 2,650+ TANKERS • 220+ MILLION DWT • MORE THAN 75% OF INDEPENDENT TANKER FLEET • 300+ ASSOCIATE MEMBERS
INTERTANKO MISSION PROVIDE LEADERSHIP TO THE TANKER INDUSTRY IN SERVING THE WORLD WITH THE SAFE, ENVIRONMENTALLY SOUND AND EFFICIENT SEABORNE TRANSPORTATION OF OIL, GAS AND CHEMICAL PRODUCTS
INTERTANKO PRIMARY GOAL LEAD THE CONTINUOUS IMPROVEMENT OF THE TANKER INDUSTRY’S PERFORMANCE IN STRIVING TO ACHIEVE THE GOALS OF: • ZERO FATALITIES • ZERO POLLUTION • ZERO DETENTIONS
AIR EMISSIONS - IMO • SEPT 1997 – IMO ADOPTS ANNEX VI TO MARPOL, REGS FOR THE PREVENTION OF AIR POLLUTION FROM SHIPS • MAY 2005 – ANNEX VI ENTERS INTO FOR INTERNATIONALLY (US AND CANADA CURRENTLY NOT PARTY) • JULY 2005 – MEPC 53 DECIDES ANNEX VI SHOULD BE REVISED TO REDUCE AIR EMISSIONS FROM SHIPS
AIR EMISSIONS IMO ANNEX VI REVISION TIMETABLE • MEPC 54 (March 2006) – Proposals for revision. The work is delegated to BLG Sub-Committee • BLG 10 (April 2006) – Initial review of the proposals and documents (over 30 documents) • Two correspondence groups (April – October 2006) • INTERSESSIONAL MEETING OSLO (November 2006) • BLG 11 (April 2007) – consider draft proposals for revised Annex VI, the NOx Code and Guidelines • MEPC 56 (July 2007), BLG 12 (Feb 2008) & MEPC 57 (March 2008) – final rounds for approval
AIR EMISSIONS • COVERED BY ANNEX VI • Oxides of Nitrogen (NOx) – create Ozone • Sulphur Oxides (SOx) – create acidification • Hydrocarbons (HC) – gas, soot and some particulates • Volatile Organic Compounds (VOC) • Refrigerant Gases • NOT COVERED (CURRENTLY) BY ANNEX VI • Particulate Matter • Carbon Dioxide (CO2) • Carbon Monoxide (CO)
AIR EMISSIONS – SOX DATE SHIP TYPE WHERE max. % S REG. 19.05.2005 All Everywhere 4.5 IMO 19.05.2006 All Baltic Sea 1.5 IMO & EU 11.08.2006 All All EU Ports EU MGO (DMA and DMX) 0.2 MDO (DMB and DMC) 1.5 11.08.2006 Passenger ships EU 1.5 EU 1.01.2007 All aux. & diesel-electric 24 miles off California shore CARB main engines on all ships MGO (DMA grade) -- MDO (DMB grade) 0.5 11.08.2007 All North Sea & English Channel 1.5 EU 22.11.2007 All North Sea & English Channel 1.5 IMO 1.01.2010 All All EU ports 0.1 EU 1.01.2010 Inland waterway ships All EU inland waterways 0.1 EU 1.01.2010 All aux. & diesel-electric 24 miles off California shore CARB main engines on all ships MGO (DMA grade) 0.1 1.01.2012 16 Greek ferries Greek ports 0.1 EU
AIR EMISSIONS PROPOSALS FOR AMENDMENTS - Lower limits for SOx & NOx emissions - SECAs with lower S cap (1.0% or 0.5%) - NOx emission limitation on existing engines - NECAs – NOx controlled areas - Restrict Particulate Matters (PM) emissions - Restrict on VOC emissions from cargo oil tanks - Restriction on CO2 emissions
AIR EMISSIONS INTERTANKO EXECUTIVE COMMITTEE GUIDING PRINCIPLES – • ENSURE A SOLID PLATFORM OF REQUIREMENTS • BE REALISTIC AND FEASIBLE • SEEK POSITIVE REDUCTION IN AIR EMISSIONS FROM SHIPS • CONTRIBUTE TO A LONG TERM AND PREDICTABLE REGULATORY REGIME • PREVENT UNILATERAL/REGIONAL REGULATIONS – IMO STANDARDS
AIR EMISSIONS • INITIAL PROPOSALS FOCUSED ON AIR EMISSIONS STANDARDS AND ABATEMENT EQUIPMENT • FUEL STANDARD WAS NOT BEING CONSIDERED • MAIN PURPOSE OF INTERTANKO SUBMISSION WAS TO “PRESENT ISSUES THAT MERIT FURTHER DISCUSSION BY IMO WORKING GROUP WHEN CONSIDERING REVSION OF ANNEX VI OF MARPOL”
AIR EMISSIONS INTERTANKO SUBMISSION • DISTILLATE FUELS WITH SULPHUR CAP: - FROM [2010], MAXIMUM OF 1% SULPHUR - FOR ENGINES INSTALLED AFTER [2015], MAXIMUM OF 0.5% SULPHUR • GLOBAL SULPHUR EMISSION CONTROL AREA • REVISION OF CHECKING AND MONITORING OF COMPLIANCE
AIR EMISSIONS IMO WORKING GROUP PROPOSALS – SOX A. Status Quo - No change B. Sulphur Emissions Control Area (SECA): • A global sulphur cap (unchanged or lower value) • SECA sulphur cap lowered in two tiers: • 1.0% in [2010] • 0.5% in [2015] C1. Change to distillate fuels (ref. INTERTANKO): • Use of distillate fuels for all ships • A global sulphur cap in two tiers: • 1.0% in [2012] • 0.5% in [2015] • Include in MARPOL Annex VI the specification for the distillate fuel to be used by ships C2. Global cap – As C1 but allows use of residual fuel + scrubbers
AIR EMISSIONS • IMO BULK LIQUID & GASES (BLG) SUBCOMMITTEE MET APRIL 16-20 TO CONSIDER THE OUTCOME OF ITS NOVEMBER WG MEETING • ADDITIONAL SUBMISSIONS MADE BY THE US, NORWAY, SWEDEN, ICS, OCIMF, BIMCO, FOEI AND OTHERS
AIR EMISSIONS USA PROPOSAL • SOx & PM – globally, consider INTERTANKO proposal for MDO [with 0.5% S cap] • SOx & PM – emission limits at [200] nm from shore as from 2011 [0.1% S cap] • NOx standards for existing (pre-2000) engines - 20% reduction • NOx for new engines: • Tier II - 15% – 25% as from 2011 • Tier III - 80% only in defined areas (NECAs) as from 2016
AIR EMISSIONS BIMCO PROPOSAL RETAIN THE CURRENT ANNEX VI STRUCTURE, BUT LOWER EMISSION LIMITS GLOBALLY AND IN SECAs GLOBALLY - 3% SULPHUR CAP IN 2012 - 1.5% SULPHUR CAP IN 2016 - USE TREATMENT TECHNOLOGIES IN SECAs SHIPS SHOULD USE MDO ONLY - 1% SULPHUR CAP IN 2011 - 0.5% SULPHUR CAP IN 2015 - ALSO USE TREATMENT TECHNOLOGIES
AIR EMISSIONS OUTCOME FROM BLG MEETING: • RETAIN 6 OPTIONS, 4 FROM WG MTG PLUS US AND BIMCO OPTIONS; AND • IMO SG WILL PROPOSE STUDY TO DETERMINE THE EFFECTS OF THE OPTIONS
AIR EMISSIONS MEPC 56 MET IN JULY 9 – 13 “NOTES” OUTCOME OF BLG 11 NEXT STEPS AT IMO: • IMO SG INITIATES STUDY • BLG WORKING GROUP MEETING IN OCTOBER IN GERMANY • BLG MEETS FEBRUARY 2008 • MEPC 57 MEETS MARCH/APRIL 2008
AIR EMISSIONS TWO BASIC ALTERNATIVES • “CLEAN” FUELS - Low sulfur residual fuel oils (LSRFO) - Distillate fuels (MDO) And/Or • SHIPBOARD TECHNOLOGY
AIR EMISSIONS LSRFO FUELS • Increase storage capacity for LSRFO • Segregation of HSFO and LSF/MDO tanks • Requires fuel switching • Additional storage for lower BN number lube/cylinder oil • Manifolds modifications for bunkering & fuel sampling • Requires the use of exhaust gas scrubbers • Availability (?) • Cost (?)
AIR EMISSIONS European refineries have no realincentive to produce LS RMFO unless the premiums are such that its price would resemble distillates Commerically speaking, refineries would have a clear incentive for further conversion of its entire residual streams to distillate products compared to residue desulphurisation to produce more LS RMFO Ship owners may just as well resort to burning MDO to meet the 1.5% sulphur cap
AIR EMISSIONS DISTILLATE FUELS (MDO) • Applies to ALL existing ships/engines • With no other measure, immediately reduces: • SOx emissions by 80% to 90% • PM emissions by 90% • NOx emissions by 10% to 15% • Reduces fuel consumption by some 4% for ALL Ships • Facilitates further NOx reductions by in-engine modifications for IMO’s Tier II & III • Eliminates the need of retrofitting of additional bunker storage capacity and associated piping • Eliminates current onboard fuel treatment plants - additional cargo volume
AIR EMISSIONS OTHER ENVIRONMENTAL BENEFITS OF MDO • SIGNIFICANTLY REDUCES ONBOARD ENGINEROOM GENERATED WASTE • “CLEANER” WASTE, FREE OF HAZARDOUS ELEMENTS FOUND IN RESIDUAL FUELS • NEGATES NEED FOR ABATEMENT TECHNOLOGY AND ASSOCIATED WASTES AND DISPOSAL OF SUCH WASTE • POTENTIAL BUNKER SPILLS SIGNIFICANTLY LESS HARMFUL
AIR EMISSIONS SAFETY BENEFITS OF MDO • LESS INCIDENTS WITH ENGINE BREAKDOWNS DUE TO POOR QUALITY FUELS • NO NEED FOR COMPLEX FUEL CHANGE OVER OPERATIONS • NO RISK OF INCOMPATIBILITY OF BLENDED FUELS • SAFER WORKING ENVIRONMENT FOR SHIPS CREW
AIR EMISSIONS UNRESOLVED ISSUESRELATED TO MDO • AVAILABILITY • COST • CO2
AIR EMISSIONS SHIPBOARD TECHNOLOGIES • Scrubber technologies are not yet proven and have their own environmental as well as economic and availability challenges • “Cold ironing” - with associated problems like lack of international standards for • voltage/frequency of power • shore/ship connection systems and • compatibility with shipboard requirements for power supply for hydraulic power sources (compressors needing up to several MW)
AIR EMISSIONS EXHAUST GAS SCRUBBERS Filters for PM Storage tank for solid waste Water waste treatment plant
AIR EMISSIONS - For a main engine of 20 MW, seawater up to 22,000 t/day needs to be processed(45 t/hr/MW*) (supplemented with some 6,500 t/day to lower pH) - Up to 100 kg/day of hazardous sludge (5kg/day/MW*) * data supplied by Krystallon
AIR EMISSIONS SCRUBBERS • EXTREMELY LARGE IN SIZE TAKING CONSIDERABLE SPACE ON SHIP • MORE THAN ONE NEEDED FOR MOST SHIPS, UP TO FOUR FOR LARGER SHIPS • MASSIVE AMOUNTS OF WATER NEEDED ON A CONTINUAL BASIS • NEW WASTE STREAM FROM SHIP THAT MUST BE DISPOSED AT SEA OR ASHORE • ADDITIONAL SHIP OPERATIONAL PROCESSES AND PROCEDURES FOR ALREADY OVERWORKED CREW
AIR EMISSIONS • SCRUBBER INSTALLATION • 4 scrubbers/ship • time to retroift – at least 30 days/ship • 100 shipyards (ships over 30,000 dwt) • RETROFIT ( 1 ship/shipyard every day): • for 10,00O ships: 8+ years • for 15,000 ships: 12.5 years • RETROFIT ( 2 ships/shipyard every day): • for 10,00O ships: 4 years • for 15,000 ships: 6+ years
AIR EMISSIONS UNRESOLVED ISSUESRELATED TO SCRUBBERS • AVAILABILITY • COST • CO2
FINAL THOUGHTS FOR THOSE THAT ADVOCATE A CHOICE FOR COMPLIANCE, ARE THEY CERTAIN THEY WILL HAVE A CHOICE?? WILL THE FUEL PRODUCERS ENSURE ADEQUATE SUPPLIES OF MDO WORLDWIDE FOR THOSE SHIPOWNERS THAT DO NOT WISH TO USE SCRUBBERS?? OR WILL ALL SHIPOWNERS HAVE TO INSTALL AND USE SCRUBBERS IN CASE MDO IS NOT AVAILABLE WORLDWIDE??
FINAL THOUGHTS WHO SHOULD BE RESPONSIBLE FOR VERIFICATION AND COMPLIANCE? • SHIPOWNER for: • Cost and installation of technology • Combustion process • Exhaust gas emission standards • Disposal of by-products OR • FUEL PRODUCER for: • Quality of fuel supplied AND • ENGINE MANUFACTURERS • Facilitate engine design that copes with a predictable rule development on lowering emissions
FINAL THOUGHTS Marine Diesel Oil ADDRESSES THE ROOT CAUSE OF AIR POLLUTION FROM SHIPS RATHER THAN THE EFFECTS OF CLEANING UP THE AIR POLLUTION ON THE SHIP AFTER IT HAS BEEN CREATED
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