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MEETING THE REGULATORY REQUIREMENTS ON AIR
EMISSIONS Chemical Carriers Association League
City, TX, November 22nd 2002 Dragos Rauta,
INTERTANKO
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Air Pollution from Ships

• Sources
• Engine emissions (SOx, NOx)
• VOC during loading
• VOC during transportation
• Legislation
• MARPOL Annex VI (adopted 1997)
• EU Directive 1999/32
• US Clean Air Act

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ASSESSING THE PROBLEM (are regulation justified?)

• Marine Engines contribute with 1.5 of NOx
  emissions (EPA, NPRM Support Document)

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ASSESSING THE PROBLEM (are regulation justified?)

• Marine Engines contribute with 1.5 of NOx
  emissions (EPA, NPRM Support Document)
• Shipping is contributing in EU with some 15 of
  the SOx and NOx emissions (UNFCCC data)

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ASSESSING THE PROBLEM (are regulation justified?)

• Marine Engines contribute with 1.5 of NOx
  emissions (EPA, NPRM Support Document)
• Shipping is contributing in EU with some 15 of
  the SOx and NOx emissions (UNFCCC data)
• Shipping is already adopting measures to limit
  these emissions and its contributions will likely
  decrease . . .
• . . . however,

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Source UNF CCC Dtatabase
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Source UNF CCC Database
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Unilateral LegislationThe EU Directive 1999/32/EU

• The Requirements of the Directive
• to Sulphur Cap all grades of Fuels within Table I
  of ISO 8217 (1996) to contain max 0.2
• (availability, compliance with SOLAS flash point,
  etc.?)
• Future considerations within the Directive
• the Sulphur Cap will reduce to 0.1 by 1st
  January 2008
• to make a Sulphur Cap proposal for HFO 1
• (refineries equipped to produce amounts required
  ?)

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Unilateral Legislation Amendments to the EU
1999/32

• IN THE NORTH SEA BALTIC
• All ships to use lt1. 5 S fuel
• THROUGHOUT THE EU
• All regular passenger vessels to use lt1. 5 S
  fuel by 2007
• IN ALL EU PORTS IN ALL EU PORTS
• All ships at berth to use lt0.2 S fuel (0.1 by
  2008)

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EU - Planed further action

• PUSH FOR TOUGHER GLOBAL STANDARDS
• As soon as MARPOL Annex VI enters into force,
  Commission will aim to submit proposal to IMO for
  tougher global engine standards, to reduce
  nitrogen oxide emissions
• EU CLEAN MARINE AWARD SCHEME
• To promote low- emission shipping and spread
  best practice
• MARKET- BASED INSTRUMENTS MARKET- BASED
  INSTRUMENTS
• Launching a new study to explore different
  market- based instruments to promote emissions
  reductions in addition to regulation e.g.
  differentiated port dues, emissions trading

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Clean Marine Award Scheme

• Awards for best practice in any or all of the
  following categories
• EU shipping companies and/or EU flagged ships
  which demonstrate continuous low-emission
  operation beyond regulatory requirements
• EU shippers which consistently charter
  low-emission vessels instead of more polluting
  modes of transport
• EU authorities, including port authorities, which
  facilitate low-emission shipping and shore-side
  activity in ports.

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Example of Market MechanismEMISSION TRADING
Source Swedish Shipowners Association
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What happens next?

• Strategy docs sent to the Parliament and Council
• Directive proposal will be subject to political
  co-decision. Negotiations could take around 2
  years before proposal adopted.
• Communication will be subject to Parliament and
  Council resolutions
• For more information, see
• http//www.europa.eu.int//comm/environment/ air/
  transport.htm

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Unilateral Legislation The US Clean Air Act

• The limits on NOx emissions
• Annex VI 10 to 17 g/kWh NOx
• EPA NPRM Tier 1 11 to 18 g/kWh NOx
• EPA NPRM Tier 2 - 7 to 11 g/kWh NOx
• EPA NPRM - smoke/particulates (not in Annex VI)
• (engines delivered from 01/2000 comply with Annex
  VI)
• Monitoring of NOx engine emissions
• Annex VI test bed before installation and maybe
  re-tests after overhauls (use MDO)/ family of
  engine
• EPA NPRM test bed monthly monitoring onboard
  the ship (use IFO HFO)/each engine

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Unilateral Legislation The US Clean Air Act - NOx

• EPA NPRM limits on NOx emissions (Tier 2) much
  lower than MARPOL Annex VI
• Four-stroke engines maybe ready to comply by the
  timeline suggested in Tier 2
• Two-stroke engines (powering 60 of the
  commercial fleet by tonnage) not ready before
  2010
• There is a misconception that ALL new engines
  perform significantly below the MARPOL Annex VI
  standards

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Existing Category 3 Engines(a 4 stroke engine
with 30 MW installed power would need 50
cylinders!!!)
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Unilateral Legislation The US Clean Air Act

• The emergency engines (generator, fire pumps,
  life boats engines) as Cat. 1 2 engines dual
  certification for US Flag ships
• Should Cat. 1, 2 3 requirements apply to non US
  Flag vessels?
• Need for dual certification

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MARPOL Annex VI additional Regulations

• Fuel Quality (not in EU Directive or Clean Air
  Act)
• the fuel shall be blends of hydrocarbons derived
  from petroleum refining. This shall not preclude
  small amounts of additives intended to improve
  performance
• the fuel shall be free from inorganic acid
• the fuel shall not include any added substance or
  chemical waste which either
• jeopardizes ship safety or impacts engines
• harmful to personnel
• contributes to air pollution

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MARPOL Annex VI additional Regulations

• Monitoring of Bunker Deliveries (not in EU
  Directive or Clean Air Act)
• The Vessel
• Bunker Delivery notes to retained for 3 years and
  available for inspection by PSC officers
• Sample to be taken of fuel delivered and
  available for PSC officers for analysis - retain
  for 1 year
• The Bunker Supplier
• to be registered
• to retain bunker delivery note for 3 years for
  inspection by PSC

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MARPOL Annex VI Challenges

• Use of LSC fuels by old engines
• Use of LSC on oil tankers boilers
• Logistics and operations for use of multiple fuel
  grades
• Repairs, spare parts and re-testing (require
  original drawings from the manufacturers for each
  component)
• INTERTANKO plans to issue guidelines (possible
  together with IACS)

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VOC Emissions at Loading

• Annex VI requires use of vapour recovery system
  at Terminals
• State regulations in US impose limitation on
  emissions during loading thus use of vapour
  recover lines at Terminals
• VOC control at off-shore loading left with
  National/States regulations (Norway by 2005,
  Delaware California in sight)

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Estimation of total VOC Emissions

• TOTAL content of some 4 to 16 VLCCs / year, of
  which
• During Loading 50 - retained by VRL
• During Transportation 50 - minimized by
  onboard measures (industry developed)
• Assessment uncertainties due to assumption for
  cargoes temperature, cargoes nature
  volatility, etc.

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VOC Emissions during transportation

• Significant amount
• No regulations in sight to limit this
• EU decided to leave this with oil and tanker
  industry
• INTERTANKO VOCON Operational Procedure October
  20001

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The VOCON ProjectLoss during Transportation
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An Operational Control to limit VOC Emissions
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VOC LAYERSDURING TRANSPORTATION(image distorted
for easy refernce)
ºC/ º F
UNSATURATED VAPOURS
INERT GAS (IG)
VOC CARGO IG
ULLAGE SPACE
VOC CARGO (vapour phase)
SATURATED VAPOURS
CARGO (liquid phase)
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VOC RELEASE AFTER FEW MIN.(DURING TRANSPORTAION)
SATURATED PRESSURE (True Vapour Pressure)
There is no need to release below the True
Vapour Pressure of the Cargo at its prevailing
liquid Temperature.
CARGO VOC (vapour phase)
CARGO (liquid phase)
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A Transportation Loss SolutionThe VOCON
Procedure
Shut The Valve Here and not Here
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Conclusions

• Urge implementation of Annex VI
• One regulation and one set of standards
• Deliver to ships Clean Quality Fuels
• Use scrubbers onshore do not transfer this
  operations to ships
• Remove nitrogen from fuels delivered to ships
• Give incentives to RD activity for new
  generations of better performant engines
• Keep things into their real perspective . . . .

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Net contribution vs. service

• ICAO (1999) Aviation transported 217 billion
  tonne-miles (combined passenger, freight and
  mail) corresponding to emission of 13.8 g
  NOx/tonne-mile
• Fearnleys review (2000) Shipping has
  transported 22,94 billion tonne-miles
  corresponding to emission of 0.89 g
  NOx/tonne-mile (16 times less than aviation)