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UPDATE ON THE REVISION OF MARPOL ANNEX VI. NORTH AMERICAN PANEL March 17, 2008 Stamford, CT. IMO Process in 2008. February - BLG finalised its contributions April - MEPC 57 to approve the revision October - MEPC 58 to adopt the revision Enforcement – earliest February 2010.

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UPDATE ON THE REVISION OF MARPOL ANNEX VI


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update on the revision of marpol annex vi

UPDATE ON THE REVISION OF MARPOL ANNEX VI

NORTH AMERICAN PANEL

March 17, 2008

Stamford, CT

imo process in 2008
IMO Process in 2008
  • February - BLG finalised its contributions
  • April - MEPC 57 to approve the revision
  • October - MEPC 58 to adopt the revision
  • Enforcement – earliest February 2010
outcome from blg 12 sox and pm emissions
Outcome from BLG 12 SOx and PM emissions
  • Three options
  • Option 1 – Global Sulphur cap
    • 4.50%
    • 1.00% as from 1 January 201[2]
    • 0.50% as from 1 January 201[5]
    • Prior to 1 January 201[2] only:
      • SECAs sulphur cap of 1.50%
      • Fuel change over procedures & timing recorded
      • Scrubbers/abatement technologies could be used as a means of compliance
outcome from blg 12 sox and pm emissions4
Outcome from BLG 12 SOx and PM emissions
  • Option 2 – Global/Regional
    • Global S cap 4.50%
    • SECA S cap
      • 1.50%
      • 0.10% as from 1 January 201[2]
    • Emissions limits for use of scrubbers:
      • 6.0 g SOx/kWh
      • 0.4 g SOx/kWh as from 1 January 201[2]
      • waste streams cannot be discharged in ports unless documented it would not have an adverse impact on the local eco-systems (IMO issues guidelines with criteria for such an assessment)
outcome from blg 12 sox and pm emissions5
Outcome from BLG 12 SOx and PM emissions
  • Option 3 – Global/Regional with Local Emissions Control Areas (LECAs)
    • Global S cap
      • 4.50%
      • 3.0% from 1 January 201[2]
    • SECA S cap
      • 1.50%
      • 1.00% from 1 January 201[0]
      • 0.50% from 1 January 201[5]
    • Emissions limits for use of scrubbers :
      • 6.0 g SOx/kWh
      • 4.0 g SOx/kWh as from 1 January 201[0]
      • 2.0 g SOx/kWh as from 1 January 201[5]
      • waste streams cannot be discharged in ports unless documented it would not have an adverse impact on the local eco-systems (IMO issues guidelines with criteria for such an assessment)
outcome from blg 12 sox and pm emissions6
Outcome from BLG 12 SOx and PM emissions
  • Option 3 – Global/Regional with LECAs
  • Proposed limits for LECAs:
    • up to [24] nm off the coast; better definition yet to be developed
    • conditions for declaring a LECA yet to be developed
    • S cap 0.10% (no date given so far)
    • scrubbers/abatement technologies allowed with the limit at 0.4 g SOx/kWh
opinions submitted to mepc 57 sox and pm emissions
Opinions submitted to MEPC 57 SOx and PM emissions
  • INTERTANKO supports Option 1
  • INTERTANKO also suggests that as from 1 January 201[5], Annex VI should also add limitiations to lower the PM emissions such as
    • carbon residue content in the fuel used by ships
    • ash content in the fuel used by ships
  • OCIMF, ICS and BIMCO support Option 3
  • IPIECA supports Option 2 but with a S cap in SECA set at 1.00%
  • Governments we believe support Option 1: Norway, Germany, Sweden, Finland, Italy, Ireland, Greece, European Commission.
possible outcome from mepc 57 sox and pm emissions
Possible outcome from MEPC 57? SOx and PM emissions
  • Possible agreement on a hybrid solution:
    • It might start with an Option 2 – like scenario
    • It then might translate into Option 1 – like scenario
  • Other comments:
    • Greece indicated at BLG 12 they disagree that scrubbers are identified as a specific alternative compliance
    • Marshall Islands seem to share that opinion
    • Australia and Canada seem also to support Option 1
    • UK suggests supporting Option 3 but it proposes amendments which may lead close to Option 1
outcome from blg 12 nox emissions pre 2000 engines
Outcome from BLG 12 NOx emissions – Pre-2000 engines
  • Measures on engines installed onboard ships constructed between 1 January 1990 and 31 December 1999
  • The NOx emissions at Tier I level
  • Applicaton date
    • at the first intermediate or renewal survey; or
    • [1 January 2010], which one occurs later
  • Compliance through:
    • in engine modification (MEPC 57 has to choose between two options); or
    • abatement technologies
outcome from blg 12 nox emissions pre 2000 engines10
Outcome from BLG 12 NOx emissions – Pre-2000 engines
  • Option 1
    • applies to all (i.e. 1990 – 1999) engines
    • if compliance through in-engine modifications not possible, a Port State could:
      • require the ship to use distillate fuel; or
      • deny port entry
  • Option 2
    • applies to larger (1990 – 1999) engines only ([displacement of and over [30/60/90] liters] or [power output of > 5000 kW])
    • use of a certified ”upgrade kit”
nox emissions pre 2000 engines intertanko fleet
NOx emissions – Pre-2000 enginesINTERTANKO fleet

168 Member Companies operating these ships

(total # of members 263)

Assuming 1 M.E. & 3 A.E. /ship there would be at least

913 M.E. and some 2, 739 A.E. (a total of at least 3,652 engines) to be modified in 3 or 4 years!!!!!

outcome from blg 12 nox emissions tier ii new engines
Outcome from BLG 12 NOx emissions – Tier II (new engines)
  • Tier II standards (emission reductions related to Tier I limits):
    • 15.5% reduction (engines with n<130 rpm) (i.e. 14.36 g/kWh)
    • reductions between 15.5% and 21.8% depending on the engine’s rpm (engines with 130 rpm < n < 2,000 rpm)
    • 21.8% reduction (engines n > 2,000 rpm) (i.e. 7.66 g/kWh)
  • Applies to engines installed on ships constructed on and after 1 January 2011
outcome from blg 12 nox emissions tier iii new engines
Outcome from BLG 12 NOx emissions-Tier III (new engines)
  • Tier III standards – 80% emission reductions from Tier I limits
  • Tier III limits apply ONLY to engines:
    • power output of > 600 kW
    • installed on ships constructed on & after 1 January 2016
    • (a Party to Annex VI can apply the above limits to new engines of 130 kW and above)
  • Tier III limits in ECAs only
  • Outside ECAs - Tier II limits
  • Emission levels for Tier III are as follows:
    • 3.40 g/kWh (engines with n<130 rpm)
    • 9*n(-0.2) g/kWh (engines with 130 rpm < n < 2,000 rpm)
    • 1.96 g/kWh (engines n > 2,000 rpm
outcome from blg 12 fuel oil quality
Outcome from BLG 12Fuel Oil Quality
  • Small but possible important changes
  • The fuels required to be ”fit for purpose”
  • MEPC 57 to clarify the meaning of ”fit for purpose” from a quality point of view
  • IMO to invite ISO to revise marine fuels specifications in ISO 8217
  • Define fuel specification for a Global solution
  • Possible inclusion of limitations of other parameters to reduce PM emissions
  • BLG developed a standard procedure to interpret the actual test results of the sulphur content of the MARPOL sample
conclusions
CONCLUSIONS
  • Possible hybrid solution for SOx and PM
    • starting with Option 2 (with a higher S cap in SECAs, say 1.00% from say 201[2])
    • followed by Option 1
  • Early dates (i.e. 2015/2016) for enforcing Option 1 would be hard to negotiate
  • INTERTANKO would be determined to avoid an outcome along the lines of Option 3
  • Fuel Oil Quality – INTERTANKO would make efforts to seek that the revised MARPOL Annex VI provides a better definition of the quality of the fuels delivered to ships
conclusions17
CONCLUSIONS
  • NOx limits for existing engines - not an easy task
  • Use of MDO would give NOx reduction by 10% to 15% BUT without a global use of MDO, the penalty on old ships would be too high
  • NOx Tier II - possible and rests with manufacturers
  • NOx Tier III implies use of SCRs/abatement technologies
  • Prudent that new ships consider compliance with Tier III and install SCRs/abatement technology prior to 2016
  • Still to be assessed
    • SCRs - the only technology to give an 80% reduction; . . . BUT
    • existing SCR technology not efficient at low engine loads
    • can compliance be achieved in ECAs irrespective of the engine load (close to port, through estuaries and straits ships slow down)?
questions

Questions?

dragos.rauta@intertanko.com