Air Emissions from Ships

1
Air Emissions from Ships
2
Society is driving the requirement for ships to
reduce harmful air emissions from engine exhausts
3
Governing Regulations

• MARPOL Annex VI entered into effect in 2005
• Baltic Sea - SECA from May 2006
• North Sea - SECA in November  2007
• Europe Sulphur Directive (1999 Rev) governs
  inter alia emissions in port (0.1 S at berth)
• California (CARB) new regulations which took
  effect Jan 2007
• Various ports
• - local regulations on Ship Emissions, which are
  inhibiting future expansion/development  
• - introducing differentiated port fees
• Of particular concern to tramp sectors, trading
  internationally, lifting bunkers in ports
  worldwide

4
MARPOL Annex VI

• Control of Air Pollution
• from Ships
• and its Current Revision process

5
Air Emissions from Ships

• 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
• Carbon Dioxide (CO2)
• Carbon Monoxide (CO)
• Engine exhaust gases are dependent upon engine
  type, engine settings and fuel type

6
The Regulations inAnnex VI

• There are 19 Regulations but the following
  Regulations impact Vessel operation
• Regulation 12 Ozone Depleting Substances
• Regulation 13 NOx emissions
• Regulation 14 Sulphur Oxide emissions
• Regulation 15 VOC emissions
• Regulation 16 Shipboard Incinerators
• Regulation 18 Fuel Oil Quality control

7
IMO Annex VI revision process

• MEPC 53 (July 2005) Decided Annex VI be
  revised
• MEPC 54 (March 2006) Proposals for revision.
  Delegated work to BLG Sub-Committee
• BLG 10 (April 2006) Initial review of proposals
  and documents (over 30 documents)
• Two correspondence groups (April October 2006)
• Intersessional Meeting (November 13-17 2006)
  discussion of key issues and draft proposals
• BLG 11 (April 2007) finalize draft proposals
  for revised Annex VI, the NOx Code and related
  Guidelines
• MEPC 56 (July 2007) MEPC 57 (March 2008) -
  consider and approve(?) the revised texts
• Target date for Entry in to Force 2010/12

8
Many proposals for significant amendments to
Annex VI

• Lower limits for SOx NOx emissions
• SECAs with lower S cap (1 or 0.5)
• NOx emission limitation on existing engines,
  particularly those installed after Jan. 2000
• NECAs NOx controlled areas
• Restriction on CO2 emissions
• Restriction on Particulate Matters (PM) emissions
• Restriction on VOC emissions from cargo oil tanks

9
Possible Guiding Principles

• prevent fragmented regulations
• promote establishment of a global standard for at
  sea, coastal and at berth operations (maybe no
  SECAs)
• international standards via IMO
• regulations based on a fuel standard rather than
  an emissions performance standard, and thus
  reduce the onus of responsibility on the
  owner/operator for verification and compliance
  (sympathy for use of clean fuels / distillates
  only)

10
Guiding Principles

• Executive Committee (June 2006) Principles for
  an INTERTANKO position
• ensure a solid platform of requirements
• be realistic and feasible
• seek a long term and positive reduction of air
  emissions from ships, and
• contribute to a long term and a predictable
  regulatory regime

11
Owners Concerns

• Multitude of differing requirements
• Additional requirements for multi-fuel usage

12
EXISTING SECAs
SOURCE http//maps.google.com/
MAY 2006
NOV. 2007
13
(No Transcript)
14
Owners Concerns

• Expanded number of SECAs, some with different
  requirements
• Proliferation of port, state and regional
  requirements often conflicting
• Installation/retrofitting of
• - multi-fuel tanks and associated systems
• - scrubber technologies, exhaust filters, etc.
  (still to be proven)
• Onboard handling and disposal ashore of toxic
  wastes from exhaust gas scrubbing in addition
  to existing sludge handling problems
• Further fuel treatment processing
• Operational and safety concerns during fuel
  switchovers
• Additional fuel log record keeping and reporting
• Onus of responsibility falling solely on the
  owner/operator

15
Owners Concerns

• Who bares responsibility for monitoring,
  verification and compliance ?
• Owner for
• Combustion process
• Exhaust gas emission standards
• Disposal of by-products
• OR
• Fuel supplier for
• Quality of fuel supplied

16
Alternative Approaches

• Do nothing retain HFO for deep sea
• Extend SECAs
• Global SECA
• Establish local SECAs
• Establish NECAs
• Use technological solutions catalytic
  converters, scrubbers and/or filters
• Burn distillates close to shore
• Cold ironing
• Emissions trading

17
An Approach

• FOR DISCUSSION
• The use of distillate fuels, with a global S
  content cap introduced using a two tiered
  programme, as follows
• from 2010, a maximum of 1.00 S content
• for ships engines installed on and after 2015,
  a maximum 0.50 Sulphur content
• A Global Sulphur Emission Control Area
• 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.

18
Alternative Approaches

• ITEMS FOR DISCUSSION include
• Future production of low sulphur fuels time
  frame
• Proving of / reliability of SCR and scrubber
  technologies
• Costs of extra bunker tanks associated systems
• Costs of manifold modifications / sampling
• Costs of additional maintenance
• Means of disposing of wash water and scrubbed
  by-products
• Suitability of blended fuels
• Net benefits
• Future costs of low sulphur HFO/IFOs

19
DISTILLATES - ADVANTAGES

• reduces all types of air emissions from ships,
  including PM
• reduces the bunker consumption (by weight) by 5
  to 10
• eliminates the need of retrofitting of additional
  bunker storage capacity and associated piping
• eliminates current onboard fuel treatment plants
  and significantly reduces onboard generated ER
  waste and exposure of the engines to damaging
  materials

20
DISTILLATES - ADVANTAGES

• eliminates the need for scrubbers for the inert
  gas system
• no additional costs of installing, operating and,
  maintaining/repairing equipment for reducing PM
  and SOx emissions
• no potential losses due to delay in case of
  unexpected breakdown of onboard technology
• if no SECAs, no operational burdens for ships
  no associated risks when changing fuel types,
  lube oils and settings for the ships engines

21
Objective of INTERTANKO submission

• The main purpose of the INTERTANKO submission is
  to "present issues that merit further discussion
  by the IMO Working Group when considering the
  revision of Annex VI of MARPOL"  
• INTERTANKO believes that it is important that
  there is open debate at the international level
  on the subject of how best to meet rapidly
  changing expectations for lower ship emissions
  and that there should be full and frank
  discussion of the various solutions possible.

22
INTERTANKO Approach

• ITEMS FOR DISCUSSION include
• Future production of distillates time frame
• Confirmation of switch-over implications
• Costs of engine conversions
• Net benefits
• Future costs of distillates

23
ONE Approach for CALIFORNIA

• Environmental achievements 2006
• Maersk Line announced a pilot environmental
  initiative that annually reduces vessel-related
  emissions from the companys fleet that calls the
  ports of Los Angeles and Oakland, USA. Maersk
  Line has voluntarily switched to low-sulphur
  diesel on the main and auxiliary engines of its
  vessels when they are within 24 miles of the port
  and alongside. Maersk Line projects a 73 annual
  reduction in particulate matter and a 92
  reduction in sulphur dioxide (SOx).

24
Options for SOx and PM Emissions (Revisions to
Annex VI InterSessional Nov 2006)

• A No change
• B Global S cap unchanged
• SECA cap 1.0 2010, 0.5 2015
• C Switch to distillates
• Global S cap 1 in 2012, 0.5 2015
• C2 As per C, with alternative such as exhaust gas
  cleaning higher S fuel (max 4.5) to obtain
  equivalent emission as in C for SOx and PM

25
Current position

• INTERTANKO encourages open debate on the options
  available to reduce damaging air emissions from
  ships and has sought to provide comprehensive
  solutions that are applicable on a global basis.
• We remain anxious that the current reviews around
  the world do not result in a mix of local and
  regional requirements that impose an onerous
  burden on international shipping, especially
  those engaged in tramp shipping - bunkering in
  and trading to ports around the world.
• We continue to stress the importance that any new
  requirements should take full account of all the
  operational and safety considerations, and should
  be assessed on the same basis - this latter
  should involve the cost and environmental
  implications of all the production,
  manufacturing, operating and waste handling
  aspects of the proposed system, as well as other
  practicalities with respect to introduction,
  fitting/retrofitting, etc.

26
For further discussion at Panel Meetings and
Councilpre BLG
27
Objective of INTERTANKO submission

• The main purpose of the INTERTANKO submission is
  to "present issues that merit further discussion
  by the IMO Working Group when considering the
  revision of Annex VI of MARPOL"  
• INTERTANKO believes that it is important that
  there is open debate at the international level
  on the subject of how best to meet rapidly
  changing expectations for lower ship emissions
  and that there should be full and frank
  discussion of the various solutions possible.

28
INTERTANKO Approach

• ITEMS FOR DISCUSSION include
• Future production of distillates time frame
• Confirmation of switch-over implications
• Costs of engine conversions
• Net benefits
• Future costs of distillates

29
Further information
30
Regulation 14 - SOx

• The Worldwide Sulphur cap on fuel oil is set at
  4.5.
• Sulphur Emission Control areas (SECAs)
• Areas Baltic, North Sea and English Channel
• Sulphur Level of fuel 1.5 or
• Alternatively use an exhaust gas cleaning system
• Ship must have cleared all pipe systems and tanks
  and be using low sulphur fuel on entry

31
Proposed Revisions of Regulation 14 - SOx

• Reduction of SOx emissions
• Reduction of the Global Cap e.g. to 3.00
• Reduction of the SECA Cap e.g. to 1.00 or
  0.50
• Correction for the reporting and measurement
  standard to two decimal places for Sulphur
  content (Bunker Delivery Note criterion).

32
Regulation 13 NOx

• For all Engines (except emergency engines)
  installed on ships after 1st January 2000 of more
  than 130 kW must comply to this Regulation.
• The NOx emission is limited to 17 g/kW h for
  engines operating at 130 rpm but reducing to 9.8
  g/kW h for 2000 rpm. Between these revs the
  limit is designated by equation
• 45 n(-0.2) g/kW h
• Existing engines can become a new engine if
  substantially modified.

33
Proposed Revisions of Regulation 13 - NOx

• Tiered approach to further NOx reductions Tier
  2 from date of revisions coming into force -
  2010, and Tier 3 from 2015
• Lower limit NOx emissions (30 - 40 reduction
  discussed for first tier 2010)
• Further NOx emission limitation on all existing
  engines, particularly those installed after Jan.
  2000
• NECAs NOx emission control areas (Tier 3 levels
  for these areas?)

34
New Parameter for Air Pollution Control

• Particulate Matter Emission control
• What are these Particulates?
• Sulphates from SOx
• Nitrates from NOx
• VOC from uncombusted hydrocarbons
• Heavy Metals e.g. Vanadium, Nickel, Aluminium,
  Sodium, Calcium, Zinc from Heavy Fuel oil and
  Lube Oil
• Soot from the aromatics in heavy fuel oil

35
Particulate Matter Regulation and Control Methods

• At present this subject matter has not been fully
  debated within the working group
• Issues to be confronted
• Size of the Particulate to be regulated 10
  micron or 2.5 micron
• Extent of limitation of Particulate emission
• Methods for control of Particulate emissions
  e.g. Scrubbers and/or Filters
• Storage and Disposal of Particulates
• Control and verification of reduced emissions

36
Current Regulation 18 Fuel Oil Quality

• 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

37
Regulation 18 Fuel Oil Quality

• Bunker Delivery Note (BDN)
• Becomes a Statutory document
• Must be kept on board for 3 years for inspection
  and a copy taken for further examination.
• 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.

38
Regulation 18 Fuel Oil Quality

• Fuel Oil Sampling
• A sealed sample meeting the requirements in
  associated guidelines has to given to the ship by
  the bunker supplier
• For each individual BDN a sample has to be taken
  at the vessels bunker receiving manifold. (see
  procedure in associated guidelines)
• The sample label has to be signed by both the
  bunker suppliers representative and the vessels
  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