New regulations for the prevention of air pollution from ships

Introduction:

 

New regulations for the prevention of air pollution from ships were introduced on 19 May 2005 as Annex VI of the International convention for the prevention of pollution from ships (MARPOL). These regulations are intended to prevent air pollution from ships by controlling emissions of Nitrogen Oxides (NOx), Sulfur Oxides (SOx), Volatile Organic Compounds (VOCs) and Ozone Depleting Substances as well as on-board combustion of ship-generated waste and quality of fuel oil used by ships. (MARPOL, 2002)

The annex is divided into three chapters where every one includes certain number of regulations. Moreover, five appendices have been added to the annex to facilitate the application by providing technical details of the requirements. (MARPOL, 2002)

This assignment is intended to provide a critical review of the annex by outlining the regulations included within it and discussing problems that could affect the application of the annex in different aspects. (MARPOL, 2002)

 

The annex contents:

 

Chapter I:

As all the other annexes of MARPOL, applications and definitions become first thing in this annex in order to build full understanding of the contents and to avoid any confusion may arise. (MARPOL, 2002)

 

Chapter II:

This chapter clearly explains the surveys, certificates and means of control required for relevant ships. All ships of more than 400 GT will be subject to initial, annual, intermediate and renewal surveys, for endorsement of the International Air Pollution Prevention Certificate which is required by this annex. However, ships of less than 400 GT may be subject to different measures to ensure that the provisions of this annex are complied with. (MARPOL, 2002)

 

Chapter III:

This chapter is the spirit of the annex as it significantly sets regulations for controlling emissions from ships into air as follows:

 

a) Regulations on controlling (SOx) emissions from ships:

 

The regulations set a global capacity of 4.5 % m/m on the sulphur content of fuel oil, a level well above the worldwide average sulphur content of about 3 percent, according to the United States Environmental Protection Agency. (Bluewater network, 2004)

What’s more meaningful is that Annex VI contains provisions allowing for special “SOx Emission Control Areas” (SECA) to be established with more strict controls on sulphur emissions. In these areas, the sulphur content of fuel oil used on board ships must not exceed 1.5 % m/m. Otherwise; an exhaust gas cleaning system should be applied to reduce the total emission of sulphur to 6.0 g Sox/kW h or less. (MARPOL, 2002)

The Baltic Sea Area is already designated as a SOx Emission Control area as well as the North Sea and the English Channel but the latter will come into force in 2007 and 2008 respectively (Europa, 2006). Other sea areas are included as described in appendix III to the annex. (MARPOL, 2002)

 

b) Regulations on controlling NOx from ships:

Annex VI sets limits on emissions of nitrogen oxides (NOx) from diesel engines with a power output of 130 kW when installed on a ship constructed or when undergoes a major conversion on or after 1 January 2000. (MARPOL, 2002)

The regulation clearly specifies the quantity of emissions permitted to be as follows:

·        If the rated engine speed (n) is less than 130 rpm, the emission should not exceed 17 g/kW h.

·        If the rated engine speed (n) is 130 or more but less than 2000 rpm, the emission should not exceed 45 x n-0.2 g/kW h.

·        If the rated engine speed (n) is more than 2000 rpm, the emission should not exceed 9.8 g/kW h.

The operation of diesel engines can also be permitted, if an exhaust gas cleaning system or other equivalent method is applied to them in order to reduce NOx emissions at least to the limits mentioned above. (MARPOL, 2002)

 

c) Regulation on controlling shipboard incineration:

Shipboard incineration is allowed only in incinerators, but incineration of sewage sludge and sludge oil generated during the normal operation of a ship may also take place in the main or auxiliary power plant or boilers, but in those cases, shall not take place inside ports, harbours and estuaries. The annex prohibits the incineration of the following substances (MARPOL, 2002):

·        Annex I, II and III cargo residues and related contaminated packing materials;

·        Polychlorinated biphenyls (PCBs);

·        Garbage containing more than traces of heavy metals as defined in annex V; and

·        Refined petroleum products containing halogen compounds.

·        Polyvinyl chlorides (PVCs), except for IMO approved incinerators.

Detailed specifications of incinerators type and operating limits are listed in appendix IV to this annex. (MARPOL, 2002)

 

d) Regulations on controlling Ozone-depleting substances:

Any deliberate emission of Ozone-depleting substances to the atmosphere is prohibited. The installation of new systems containing ozone depleting substances will not be allowed after 19-5-2005, except HCFC (R-22), which can be installed up to 1 January 2020. (MARPOL, 2002)

 

The substances, when removed from a ship, are to be delivered for proper handling to reception facilities i.e. ports (MARPOL, 2002).

 

 

 

e) Regulations on controlling Volatile organic compounds:

Tankers and gas carriers which load substances generating VOCs shall be provided with a vapour collection system and use the system during loading of cargoes in designated ports/harbours which are subject to vapour emission control. (MARPOL, 2002)

Fuel oil combustion is the major source of the above mentioned emissions (Wikipedia, 2006) and therefore, the annex pays particular attention to the quality of fuel oil used by ships to ensure that it complies with the standards of sulphur contents corresponding with each area. (MARPOL, 2002)

Ships of 400 gross tonnages or above engaged in international voyages shall keep on board the bunker delivery note and sample for a certain period of time (MARPOL, 2002).

To gain full advantage of air pollution prevention regulations, platforms and drilling rigs are also required to comply with the requirements stated in regulation 19 of the annex. (MARPOL, 2002)

 

The mechanism of reducing NOx and SOx emissions:

Ship owners have three major options to reduce emissions of SOx: switch fuels, install a scrubber (1), or improve fuel efficiency (NERA economic consulting, 2005). On the other hand, Ship owners may have more options available to reduce NOx emissions than SOx emissions, including installing selective catalytic reduction (“SCR”), direct water injection (“DWI”) or humid air motor (“HAM”) technologies, making internal engine modifications, or installing a new engine. (NERA economic consulting, 2005)

However, the specific nature of vessel activity can have a significant impact

on which technologies will be most cost effective. Similarly, the nature of the policy requirements, and in particular the region over which emissions are considered to be of

 

 

_______________________________________________________

(1) A scrubber is an emissions control technology commonly termed flue gas desulphurization or “FGD”

that can be installed to reduce SOx and other emissions. (NERA economic consulting, 2005)

concern, can also dramatically alter the incentives for installing particular technologies. (NERA economic consulting, 2005)

 

Issues associated with the enforcement of Annex VI:

 

1) Other similar pollutants:

 Carbon Oxides, hydrocarbon, particular matter and smoke emissions are considered to be common pollutants and ships produce large quantities of them but, yet have not been addressed in the body of the annex (Colin S. Brookman, 2002). Therefore, Baltic marine environment protection commission (MEPC) is expected to establish a working group to consider issues relating to the prevention of air pollution and emission of the above mentioned gases. (Baltic & European news, 2006)

 

2) Reception facilities:

Inadequacy of Port Reception facilities is another issue that has to be solved in order to achieve full compliance with MARPOL. Consequently, the MEPC, via IMO, is expected to approve a proposed draft action plan to tackle this issue effectively. (Baltic & European news, 2006)

 

3) Low-sulphur marine fuel:

Possible engine problems resulting from prolonged consumption of low-sulphur marine fuel oil have been identified by marine fuel experts (Rudolph Kassinger et al, 2005). One of these problems is the accelerated wear caused by the building up of Acid or Alkaline situation (Signals, 2005).

Another problem may arise when the charter party gives the charterer the option to nominate discharge port out of one or more wide geographic ranges after the vessel has left the port of loading. In this case the vessel may have to change course to find compliant fuel to enable it to reach and enter SOx Emission Control Area. Accordingly, the owner will be looking to recover additional freight and increased bunker costs (Signals, 2005).

Taking into consideration the potential problems with uneven geographical distribution of low-sulphur marine fuel as only South America (Argentina, Brazil, Chile, Colombia and Ecuador), West Africa and Indonesia are average marine fuel sulphur content equal to or less than 1.5%. These locations are not ideal for meeting the requirements of this annex when entering SOx Emission Control Area (Rudolph Kassinger et al, 2005).

 

4) Flags of convenience:

The annex clearly states that the surveys and certifications are to be carried out by the Administration, which is in this case the state under whose authority the ship is operating (MARPOL, 2002). The top five merchant fleets all over the world are registered with flag of convenience nations (Bluewater network, not dated). By relating the number of ships registered with flag of convenience nations and the requirements of the annex, a weak implementation can be indicated and therefore, the annex may not be enforced properly.

 

The future predictions:

The need for undertaking a review of Annex VI is justifiable in order to cover areas which can improve the efficiency of the Annex and as a result, the MPEC agreed to do so. The review will consider relevant technologies and the potential for a reduction of NOx and SOx emissions and recommend future limits for controlling. Moreover, it will consider the possibility of controlling VOCs emissions from cargoes. Finally, the review will discuss the standardization of on-shore power supply connections with ships (IMO, 2006).

 

Summary:

MARPOL Annex VI covers a wide range of air pollution matters, including the controlling of NOx and SOx emission, Ozone-depleting substances, ship board incinerations and VOCs. As any other new regulation, Annex VI has issues connected to the means of implementation which were discussed briefly. Finally, the Annex will be reviewed over and over in order to gain full advantage of the air pollution preventing regulations.

Credit:ivythesis.typepad.com