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MARPOL Annex VI
Regulations for
the Prevention of Air Pollution from Ships
INTERTANKO LATIN AMERICAN PANEL
November 16, 2005
Miami Beach, Florida
RATIFICATION
• 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.
IMPLEMENTATION
Mission impossible?
• 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
Certification & Survey under Annex VI
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 drydocking but not later than 05/18/2008
Survey
• Intial
• Periodical (5 years)
• Intermediate
• Annual
MARPOL Annex VI
• Scope: Control of exhaust gas emissions from ships
• Regulations for limiting/eliminating emissions of:
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Ozon-depleting substances
Nitrogen oxides (NOx)
Sulphur oxides (SOx)
Volatile organic compunds (VOC)
Shipboard incinerators
• Additinal requirements for:
– Reception facilities
– Fuel oil quality
Ozone-depleting substances
• 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
Nitrogen Oxides (NOx)
• 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%
Technical File
• 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
Sulphur Oxides (SOx)
• Sulphur content of bunkers should not exceed
– World wide trade
– Baltic Sea (from 05/19/2006)
– North Sea (from 10/2007 or 08/2007)
• Alternative exhaust gas cleaning on:
– funnel
– IG scrubbers
4.5%
1.5%
1.5%
Shipboard Procedures for SECAs
• 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.
Action
Advantage
Disadvantage
Timely switch over
No equipment
Excessive use of LSF
HFO & LSF in
segregated tanks
Rapid change over
Lower LSF consumption
Retrofitting needed
Use of scrubbers
Reduction 90% of SOx
Use of HFO only
Technology yet to be
approved
Ship to demonstrate no
environmental impact
Initial costs
Sludge deposits
Onboard blending
Keeps costs down
Simpler tank arrangement
Liability of compliance on
the ship
Need for a blending plant
Emission Trading
If often operating in SECAs System not in place
Use of HFO
Questionable whether
allowed for a long period
ALTERNATIVES for SECAs
Volatile Organic Compounds (VOC)
• 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
Incinerators
• 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.
Operation of Incinerators
• 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.
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”
Fuel Oil Quality
• 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
Declaration on Fuel Oil Quality
• 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.”
Fuel Oil Quality - Sampling
• 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
Shipboard Procedures for
BDN and Samples
• 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
Bunker Emission Clause for time charters
1. 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.
2. 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.
3. 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.
Port State Control
• 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
Onboard certificates & documentation
• 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
INTERTANKO Guide to bunkering of ships for the purposes of
Annex VI to MARPOL, June 2004
• ANNEX VI OF MARPOL - REGULATIONS
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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
MARPOL Annex VI
future developments/amendments
• 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
Regional Requirements
• 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