marine environmental protection legislation

MARAN GAS MARITIME INC

ANANGEL MARITIME SERVICES INC. KRISTEN NAVIGATION INC.

SEMINAR:MARINE ENVIRONMENTAL PROTECTION LEGISLATION

INTRODUCTION TO ISO 14000 STANDARD

• MARPOL Annex VI-Regulations for the Prevention of Air Pollution

• The 1999 EC Directive on Fuel Sulphur and amendments.

• Refrigerants and fire fighting agents – current EU and MARPOL legislation.

• Antifouling paint certification and future regulations.

• The International Convention for the Control Management of Ships Ballast Water and Sediments.

• Recycling of Ships, the IMO Guidelines and the ‘Green Passport’ scheme.• Recycling of Ships, the IMO Guidelines and the ‘Green Passport’ scheme.

• Environmental Protection Notation.

Prepared by: D.DOUMANIS/G.KRIEZIS

January 2005

CERTIFIEDMARITIME TRAINING CENTRE

ANANGEL/KRISTEN/MARAN GAS Training Dept. has been certified by DNV under the

provisions of DNV “Rules for Maritime Training Centers” with a certificate No: 113443.

Marine Environmental

Protection Legislation

• Control of air pollution

• ISO 14001

• Anti-fouling systems• Anti-fouling systems

• Ballast water management

• Ship recycling and IMO guidelines

• Environmental protection notation

Annex I Prevention of pollution by oil

Annex II Control of pollution by noxious liquid substances

Control Of Marine Pollution -

MARPOL

Annex III Prevention of pollution by substances in packaged form

Annex IV Prevention of pollution by sewage

Annex V Prevention of pollution by garbage

Annex VI Prevention of air pollution from ships

MARPOL Annex VI Prevention

of Air Pollution From Ships

• Entered into force on 19 May 2005

• Which ships does it apply to?

• What does it cover?• What does it cover?

• How do you comply?

• Future developments

MARPOL Annex VI & EC Fuel

Sulphur Directive

• Aim of Annex VI-MARPOL 73/78

• Annex VI-Brief Historical Overview

• Annex VI-Regulation 13-NOx

• Annex VI-Regulation 14-SOx

• Annex VI-Regulation 18 Fuel Quality & • Annex VI-Regulation 18 Fuel Quality &

Sampling/Bunkering Requirements

• European Council Directive 1999/32/EC

• Low Sulphur-Technical Implications

• Liner Lacquering

• Alternatives

• Conclusions

Aim of Annex VI-MARPOL 73/78

• To deliver a significant reduction in ship (harmful)

emissions’ contribution to acidification and emissions’ contribution to acidification and

consequently improve air quality’.

Annex VI- Brief Historical Overview

• Between 1972-1977 studies confirmed the hypothesis that air pollutants

could travel thousand kilometers before deposition (&damage) occurred.

• The 1972 UN Conference on the Human Environment in Stockholminitiated the beginning of active international cooperation in tackling

acidification/acid rain.acidification/acid rain.

• In 1979 the Convention on Long-range Trans-boundary air pollution wassigned by 34 Governments and the EU.

Protocols to the 1979 Convention were later signed on:

Reducing Sulphur emission (1985)

Controlling emissions of nitrogen oxides (1988)

Controlling emissions on VOC (1991)

Further reducing sulphur emissions (1994)

• The protocol of 1997 (the new Annex VI of MARPOL 73/78)

Annex VI-MARPOL 73/78 (1997)

Main Focus on the following points:

• Applicable to ships of 400gt and above.

• Nitrogen Oxides Reduction (NOx)

• Sulphur Oxides Reduction (SOx)

• Volatile Organic Compounds (VOCs)

• Chlorofluorocarbons (CFCs)

Pressure on Shipping Emissions

• There is strong political pressure for Emissions Reductions

• Health impacts becoming more important & easily measured.

• Contribution of Shipping to SOx emissions becoming a significant proportionof overall emissions

• Cost of Sea reductions is less than other options

• Annex VI is one step to the right direction, however will not resolve the issueof shipping emissions.

Environmental Impact

• According to research conducted by IMO sulphur emission from ships’

exhaust is estimated at 4.5-6.5 Million tones/year=4% of total global sulphur

emissions.

European Council Directive

1999/32/EC

• In 1979 the Convention on Long-range Trans-boundary air pollution was signed by 34

Governments and the EU.

• In 1993 established Directive 93/12/EEC

• In 1999 amendment of directive 93/12/EEC and a new Directive 1999/32/EC established.

• Amended 1999/32/EC [com(2002)595] expected?• Amended 1999/32/EC [com(2002)595] expected?

Existing EU Regulation 1999/32/EC

• Initial directive 1999/32/EC applies only to distillate fuels (DMX,DMA,DMB,DMC grades).

• Specifies that ships in the European community area (territorial waters, including 12 nautical

miles from shore and inland waterways) should use distillate fuels with sulphur content 0.20%

m/m maximum.

• Distillate fuels with Sulphur content Lower than 0.1%m/m max.should be used by January

2008 onwards.

Amendments on 1999/32/EC-

[COM(2002)595)

• Designed to be inline with Annex VI-MARPOL 73/78.

• Maximum 1.5% sulphur limit for fuels used by all ships in the Baltic Sea, North Sea &

Channel.

• Today’s political agreement incorporates this provision, and sets implementation dates• Today’s political agreement incorporates this provision, and sets implementation dates

starting in 19 May 2006 for the Baltic Sea.

• Maximum 1.5% sulphur limit for fuels used by passenger vessels on regular services

between EU ports, from 1 July 2007.

EU Ministers also rubber stamped this and brought the deadline forward to 19 May 2006.

• Maximum 0.2% sulphur limit on fuel used by inland vessels and by seagoing ships at

berth in EU ports. The Council agreed a tighter 0.1% limit delayed until 1 January 2010, to

allow single-fuel ships time to adapt their fuel tanks.

• A further two year delay was offered to 16 unifuel ferries serving the Greek islands.

Factors to Consider

• Impact on the shipping industry (commercial).

• Impact on the Bunker Industry (&what this implies??).

• Impact of the Expansion of EU member states.• Impact of the Expansion of EU member states.

• Availability of Low sulphur fuels.

• Impact on storage on the ship (for both Fuels & Lubricants)

• Technical impact, assessment of the impact on the Machinery

plant.

MARPOL Annex VI-Application

• All Ships 400 gross tonnage and above, fixed/floating drilling

rigs & other platforms-subject to survey

• New ships-from 19 May 2005

• Existing ships-no later than first dry dock & within 3 years (ie by 19 May 2008)

• Does not apply when:

Securing safety of ship

Saving life at sea

Suffering damage to ship or equipment

MARPOL Annex VI-requirements

• Ozone depleting substances (ODS)

• Nitrogen oxides (NOX)

• Sulphur oxides (SOX)

• Volatile Organic Compounds (VOC)

• Shipboard incineration

• Fuel oil quality

Ozone Depleting Substances

• Prohibits new installations containing ozone depleting

substances eg CFC refrigerant gases & halon fire fighting

agents (except HCFC until 1 Jan 2020-but banned by other

legislation!)

• • Existing ships can retain halons & other ODS until

replaced or required to be moved by international, national

or other requirements.

• Prohibits deliberate emissions eg during maintenance,

service or repair.

• Requires ODS removed to be delivered to reception facilities.

Volatile Organic Compounds (VOC)

• Controls volatile emissions from tanker cargo tanks during loading/unloading.

• Requires Vapour Emissions Control System (VECS) • Requires Vapour Emissions Control System (VECS)

compliant with MSC/Circ. 585 on Standards for VECS

systems.

• Applicable in designated ports and terminals with

appropriate systems only.

Shipboard incineration of waste

• Applicable to incinerators installed on/after 1 January 2000.

• Requires compliance with IMO specification for shipboard

incinerators MEPC 76 (40)

• Minimum flue gas temperatures

• Prohibits incineration of:

MARPOL Annex I, II & III cargoes

Polychlorinated biphenyls (PCB)

Garbage containing heavy metals

Refined petroleum products containing halogens

Engine NOx emission regulation –

Regulation 13

• Covers all diesel engines with power output>130 Kw (except

emergency or lifeboat engines).

• Applies from 1 January 2000 delivered ships• Applies from 1 January 2000 delivered ships

• Variable NOx emission limits dependent upon engine speed. (From 17 gNO2/kWh to 9.8 gNO2/kWh depending on rated

engine speed)

Engine NOx emission-certification

•Test bed exhaust emission measurement and setting of

parameters

•NOx Technical File (info on components, settings, operating

values & allowable adjustments to maintain NOx emissionsvalues & allowable adjustments to maintain NOx emissions

within acceptable limits)

• Engine International Air Pollution Prevention (EIAPP)

Certificate/ Statement of compliance & approved NOx

Technical File issued.

New ships – this done during sea trials

Ships build since 2000 – TF available - Statement of

compliance converted to EIAPP certificate at first drydock or

latest on 19/5/08

Engine NOx emission-onboard

survey

• On-board verification survey after installation as part of initial

IAPP survey. Various methods:

Engine parameter (MAN B&W SL03-428)

Simplified measurement (Measure emissions onboard with

suitable instruments – for old engines)

Direct measurement & monitoring (Continuous onboard

monitoring)

• Annual, (intermediate) & renewal surveys as part of overall MARPOL Annex VI survey.

Parent Engine

• Parent engine – Measure emissions & establish tolerances on performance data

• Establish NOx components• Establish NOx components

• Measure performance data (Pmax, Pcomp, Tscav, Turbo back pressure) on testbed and establish sensitivity of changes to these parameters to level of NOx

emissions

Member Engine

• Do performance check to ensure all

measurements are within the limits

established on the Parent testbed resultsestablished on the Parent testbed results

• Check and ensure all NOx components

are correct and marked as such

• No need to measure emissions

NOx Components

MAN B&W slow speed engines – 11-12 standard engine components selected and marked with their IMO number (usually part no)

• Fuel nozzle (most influence and easier to check)

• Fuel pump plunger and barrel

• Cylinder liner, cylinder cover, piston crown

• Fuel cam and exhaust cam

• Scavenge air cooler

• Auxiliary Blower

• Turbocharger

• Governor (as applicable)

Examples of Nox components

IMO NOX Technical file

• Class approved document – Changes need

approval

• Specifies actual engine performance data

• Specifies IMO components relevant to NOx

• Includes instructions on how to check the

engine (from manual)

• Keep “Engine Record book of engine

parameters” for all changes – E/R Log

NOx survey requirements

• Any replacement of IMO components should

be done by maker authorized parts properly

marked. Record of maintenance/ replacement

should be made (E/R log book).should be made (E/R log book).

• Sensors and gauges used to verify parameters

of the engine must be reliable and calibrated.

• Tolerances of performance parameters to be

kept after correction to ISO ambient conditions

(Pmax, Pcomp, Tscav, Turbo back pressure)

Implications of NOx emissions

• Substantial modifications need approval to ensure NOx emissions are not increased.

• Maker amendments need to be type-• Maker amendments need to be type-approved (eg. Slide fuel valves)

• Reconditioning of IMO parts by authorized repair shops

• Maintenance as per maker’s manual

Annex VI-MARPOL 73/78 (1997) – Fuel

Quality - Regulation 18

• Fuel quality to meet requirements in ISO 8217International Marine fuel standard. 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

Annex VI-MARPOL 73/78 (1997) –

Regulation 18 (cont)

• Bunker receipts should include Vessel’s IMO number, name, port,

bunkering date, quantity, grade, density and sulphur content.

• A declaration that the fuel oil supplied is in conformity with regulation 14(1)or (4)(a) and 18(1) of Annex VI should be signed by the fuel supplier.or (4)(a) and 18(1) of Annex VI should be signed by the fuel supplier.

• The bunker delivery note should be accompanied by a representative fuel oilsample of the fuel delivered to the ship.

• Guidelines as to how a representative drip sample is obtained are defined inMEPC 96(47).

• Both the vessel and the fuel oil supplier should retain the bunker receiptsfor a period of three years after the fuel oil has been delivered to the vessel.

Annex VI-MARPOL 73/78 (1997) –

Regulation 18 (cont.)

• Bunker delivery notes should be available for inspection at any time.

• Samples should be retained on board ship for at least 12 months since theday/time of delivery.day/time of delivery.

• When operated in SECA zone ships should allow sufficient time prior tochange over to low sulphur (<or=1.5%m/m) fuels.

• The volume of low sulphur fuel in the tank as well as the date, time andposition of the ship when any fuel change operation is completed should be

recorded in a log book.

Annex VI-MARPOL 73/78 (1997) SOx

– Regulation 14

• Annex VI (SOx) will be enforced on 19/05/2005

• Applicable to all fuel oil on board ships

• 4.5% M/M (Max) Sulphur Global Cap

• 1.5% M/M (Max) Sulphur @ SOx Emissions Control Areas (Known as SECA

zone)

• SECA zone includes (Baltic Sea, North Sea & English Channel)

• Currently the only SECA Zone is Baltic Sea

• Baltic Sea-12 months grace period after Annex VI enforcement (19/06/2006)

• Alternatively ships must fit an Exhaust Gas cleaning system (which can restrict

sulphur emissions to 6.0 g/KWh)

Low Sulphur-Technical Implications

• Specifically for Uni-fuel HFO ships designed for one fuel type.

• Difficult to maintain seal integrity (H.P. Fuel oil P.P)

•Very low sulphur-Lubricity compounds reduced-Fuel pumps/injectors•Very low sulphur-Lubricity compounds reduced-Fuel pumps/injectorsvulnerable.

• Steam plants-Difficulty to adopt to high load boiler operational requirementswhen operate boilers on Gas Oil (i.e. Discharging conditions)

• Cylinder Oil Base Number (BN)-to Sulphur content.

• Implications on change procedures

• Liner Lacquering-Increased cylinder deposits-bore polishing-loss of oilcontrol.

Effects of Lacquering

• Lacquering and polishing may result to increased cylinder lubricating oil

consumption.

• Higher operational cost.

• Lubrication may be ineffective resulting to high temperatures and damage ofpiston rings, liners etc.

• ΤΤΤΤhe problems are more apparent to modern engines operating at highpressures (especially modern medium speed engines with high BMEP (Brake

Mean Effective Pressure)

• Lacquering is more favorable when the engine is operated above MCR(Maximum Continuous Rating) for extended periods with the duty cycle

changing from high to low loads.

Alternatives for SOx reduction

• Sea Water Exhaust Gas Scrubbers.

• HFO Blending.

• Increase Import volumes of Low sulphur crude oil.• Increase Import volumes of Low sulphur crude oil.(Brazil, South America etc).

• Desulphurisation through the refining process.

• Fuel Oil/Gas oil tank segregation on board ships.

• Use low sulphur fuel (e.g. 1.5% M/M max. limit) worldwide.

• Emission Credit Exchange System.

Alternatives-Sea Water Exhaust Gas

Scrubbers• Sea Water Scrubbers Effectively reduce SOx of Exhaust Gases. Pilot program

between P&O cruises and BP.

• System’s Efficiency at the moment is around 90%

• Capital Investment is required as well as viability study for existing/old ships.

• More consideration on Sea water pollution & monitoring should be given.• More consideration on Sea water pollution & monitoring should be given.

• Complexity of the system.

• Operation and maintenance (due to corrosive nature of both sea water & Exhaust

Gases)

• Exhaust Gas monitoring/Recording system should be in place.

• Class/Port authorities inspection will be required.

• Economic evaluation is required.

Sea Water Scrubber System Efficiency

• Efficient gas/water mixing in a compact space.

• Cleaning of scrubbing water before discharge

• Further reductions of NOx & Particulates

Emissions Efficiency

SOx

90%

NOx

15%

Particulates

80%

Blending

• Blending requires specific consideration and calculations.

• The fuels blended should be compatible.

• Can easily result to incompatibility and consequently operational • Can easily result to incompatibility and consequently operational problems on board.

• May encourage in-line blending during delivery (depending on supplier’s policy).

• Poses increased risk with respect to compatibility and homogeneity compared to non blended fuels.

• Fuel & Cylinder Lubricating oil segregation.

Increase Import volumes of Low sulphur

crude oilIncrease Import volumes of Low sulphur crude oil may have the following

Implications:

• May affect availability.

• Increased cost-May Have a spiral effect on the bunker pricing consequently affecting ship owners/operators.

• Increased number of ships entering EU waters.

• Highly dependent on OPEC’s Production Plan.

• Limitations with regards to local legislation.(highly dependant on the geographical area) i.e. Brazil-Petrobras


• It is likely to have a spiral effect on the F.O price

Desulphurisation through the refining

process

• Quality Assurance requirement.

• Time consuming Process.


• Estimated additional cost will be around 40 $ to 60 USD/MT

• Increased cost will be due to high cost of Hydro treatment and the high capital cost requirements for hydrogen gas.

• Increased cost. It is estimated that fuel oil desulphurisation will cost the industry approximately 1 billion $ USD.

• Who is finally covering the additional cost?

Fuel Oil/Gas oil tank segregation

• Consideration at the design stage (concept stage).

• Position of the tanks.

• Increased risk since crew will have to manage possibly 4 different grades of fuels and 2 different grades of Cylinder

Lubricating Oil on board.

• Less Engine room/Cargo Space.

• Increased system complexity.

Use low sulphur fuel (1.5 %) worldwide

• Will affect availability.

• Increased cost.

• Highly dependent on OPEC’s Production Plan.

• Consideration of Technical issues required.

Emission Credit Exchange System

The scope of the trading system:

• To create the same or greater emissions reduction than the one proposed in EU

policies and regulations by including shipping within EU and transit traffic.

• To create the reductions of the lowest economic cost for all parties involved, directly or

indirectly.indirectly.

• To create financial incentives for the shipping sector to reduce SOx emissions.

• Possible in theory but difficult in application.

• Needs a lot of investment and effort

• Will need an operational base accepted by everybody.

• Requires good co-operation between Port State Controls (and ship owners) to monitor

the trading routes of ships.

Conclusions• Both Annex VI-MARPOL 73/78 and the amended 1999/32/EC

will have a huge impact on the fuel quality delivered to ships.

• Fuel suppliers will be forced to supply a better quality fuel.

• Storage requirements for both fuel oil and cylinder lubricating

oil will be affected.

• Fuel oil cost is likely to increase (Desulphurisation at an extra

US$ 40 – US$ 60/MT).

• Additional requirements for both ship’s crew and shore based

personnel.

• Independent Testing Services may be required for quality assurance.

MARPOL Annex VI-compliance

summary• New ships (from 19 May 2005)

Non-ozone depleting refrigerant gases & fire fighting agents; include operational

requirements to prevent emissions during maintenance etc and disposal requirements in

company procedures.

Incinerator certificate or statement of compliance with IMO/MEPC 76(40) design

requirements (if fitted); incorporate operational requirements in company procedures.requirements (if fitted); incorporate operational requirements in company procedures.

Vapour Emissions Control System certificate or statement of compliance with

MSC/Circ.585 (if fitted).

Engine International Air Pollution Prevention (EIAPP) certificate or statement of

compliance with NOx emissions limits in Annex VI & NOx Technical File-applicable

diesel engines.

Formulate strategy for compliance with SOx emissions requirements. Specify design

requirements consistent with strategy. Specify fuel quality requirements in operational

procedures for SOx emissions control & maintenance of fuel quality.

MARPOL Annex VI-compliance summary

• Existing ships (first dry dock & latest 19 May 2008)

Continued use of ozone depleting refrigerant gases & fire fighting agents not prohibited, but

check other international and national legislation. Include operational requirements to prevent

emissions during maintenance etc and disposal requirements in company procedures.

Incinerator certificate or statement of compliance with IMO/MEPC 76(40) design requirements

for incinerators installed on/after 01/01/2000; Incorporate operational requirements in company

procedures.(Usually exists).procedures.(Usually exists).

Vapour Emissions Control Systems certificate or statement of compliance with MSC/Circ.585

(if fitted). Individual ports/terminals may waive requirement for up to 3 years. (Usually exists in

our fleet).

NOx emissions requirements not applicable to engines built or installed pre 01/01/2000.

Relevant engines built or installed as from 01/01/2000 need statement of compliance or EIAPP

certificate & NOx Technical File (difficult retrospectively). (Most of our ships already have this

file).

Formulate strategy for compliance with SOx emissions requirements. Implement design

modifications consistent with strategy. Specify fuel quality requirements in operational procedures

for SOx emissions control & maintenance of fuel quality.

MARPOL Annex VI-certification

• All ships>400gross tones, fixed & floating drilling rigs & other

platforms require survey & International Air Pollution Prevention

(IAPP) certificate.

• Flag administration may establish alternative requirements for

ships<400 gross tones.

• IAPP valid 5 years from initial survey

• Annual, (intermediate) & renewal surveys

MARPOL Annex VI-surveys

• Initial survey onboard

New ships- ensure Builders’ working drawings consistent with

approved plans.approved plans.

Existing ships-determine applicable requirements.

Ensure equipment, system, fittings, arrangements & materials

fully comply (with applicable requirements)

Survey checklist completed & IAPP Certificate or Certificate of

Compliance issued.

MARPOL Annex VI-surveys

• Annual survey

Verify certificate in order

Examine & test selected equipment-establish adequate condition &standard

of maintenance

Endorse IAPP certificate

• Renewal survey

Ensure equipment, system, fittings, arrangements and materials fully comply

with requirements

New IAPP certificate issued. Valid 5 years

• Intermediate survey?

Control air pollution-future developments

• MARPOLAnnex VI

More SECAs?

Decreased fuel Sulphur limit globally & in SECAs?

Lower engine NOx limits.

Additional emission components-particulates?Additional emission components-particulates?

Greenhouse gas (GHG) emissions

Main focus CO2 - directly linked to fuel consumption, international

shipping emissions excluded from international agreements.

CO2 emissions/tones/mile

Ten years time frame

Control air pollution-future developments

• European Community

Fuel sulphur directive and amendments

No additional measures at present for NOx-but if no definite measures for

further NOx reduction at IMO, EC likely to act.

Push to include international shipping in CO2 emissions trading from 2012.

VOC emissions considered relatively low than other sources & currently no

proposals to regulate.

REFRIGERANTS AND FIRE-

FIGHTING AGENTSFIGHTING AGENTS

Refrigerants & Fire Fighting AgentsRefrigerants – overview

• Legislation – Why?

• Terminology and definitions.

• Refrigerants – Family Tree.• Refrigerants – Family Tree.

• Refrigerants where used in marine applications

• Legislatory bodies – IMO, Flag Sates, Montreal Protocol and European Union.

• What should we do? – existing and new tonnage.

Terminology

• Atmospheric Life/Ozone Depletion Potential (ODP):

This is the time taken before the released refrigerant decomposes down to

its constituent elements.

Natural compounds with short atmospheric lifetimes will degrade near their Natural compounds with short atmospheric lifetimes will degrade near their

point of release, such as hydrocarbons and ammonia.

With CFCs and HCFCs it is only once they reach the stratosphere and the

chlorine content is subject to the sun’s high energy ultraviolet radiation will

they start to decompose.

This process can last many if not hundreds of years.

Global Warming Potential (GWP)

This is another relative figure and is the term given to the upward

climatic change attributed to CO2, methane, nitrous oxide, CFCs

etc. being released into the atmosphere and absorbing infrared etc. being released into the atmosphere and absorbing infrared

radiation which would otherwise escape into space.

The figures are based on the total calculated global warming due

to the emission of a kilogram of the refrigerant divided by the

total calculated global warming due to the emission of a kilogram

of CFC R11.

Montreal Protocol –Ozone depletion

• Montreal Protocol initiated 16 September 1987

• Ozone Depletion

Kyoto Protocol – Global warming

• Kyoto Agreement adopted 09 May 1992

Not yet fully ratified – stalled by United States. Russia has decided to

ratify the protocol by this year

Refrigerants – Family Tree

CFC

Chlorofluorocarbon

Production Ban 1996

Article 5 countries 2010

HCFC

Hydrochlorofluorocarbon

Traditional Substance

Banned in new plant

HFC

Hydrofluorocarbon

Ozone Friendly

Under Question

Environmentally

inert

Natural Substances

R11

ODP =1.0

GWP = 4000

R12

ODP = 10

R22

ODP = 0.055

GWP = 1700

R141b

(Foam blow)

R410A

ODP = 0

GWP = 1890

(High Pressure)

R404A

Ammonia

ODP = 0

GWP = <1

CarbonODP = 10

GWP = 8500

R115

(R502)

ODP = 0.283

GWP = 5591

(Foam blow)

ODP = 0.11

GWP = 630

R404A

ODP = 0

GWP = 3748

(High GWP)

R507

ODP = 0

GWP = 3800

(High GWP)

R407C

ODP = 0

GWP = 1610

Flammability?

Carbon

Dioxide

ODP = 0

GWP = 1.0

Propane/

Isobutane

ODP = 0

GWP = 3.0

Legislation

Current

• Montreal Protocol – covers all ozone depleting substances and their production phase out.

• Regulation (EC) No.2037/2000 – covers ozone depleting substances – their use and also emission control (recovery) within EU.

• EN 378 – Refrigeration systems and heat pumps – Safety and environmental requirements.

• Flag State requirements such as Cyprus – totally prohibiting the use of ozone depleting substances, such as HCFC R22, on existing ships as from 2008

Enacted

• IMO MARPOL Annex VI,

Annex VI has been ratified and came into force on 19 May 2005

Regulation 12 specifically targets ozone depleting substances, their

deliberate emissions and removal from the ship.deliberate emissions and removal from the ship.

• Flag State requirements

Proposed Legislation

• Kyoto Protocol – covers global warming potential from a ‘basket of

greenhouse gases’.

• European Climate Change Programme – covers emissions and use restrictions of Fluorinated gases, CFCs, HCFCs and HFCs (‘F-gas

Regs’)

• IMO MEPC 46/INF.29 Prevention of Air Pollution from Ships –Recommendations submitted by Friends of the Earth International.

• Release of hydrocarbons (VOCs) to the atmosphere.

Refrigerants

• Definition of “Use” as per regulation (EC) 2037/2000:

“The charging, topping up and removal of refrigerant from the system or

equipment.”

•••• What is not construed as Use:

The circulation of the refrigerant within the system is not considered as

“use”

Thus the continued use of CFCs and HCFCs refrigerants in existing

systems after their final ban date will not, as of today, be legislated against.

Refrigerants

Existing ships

• Continue to use HCFC R-22

The use of HCFC R-22 in existing systems will continue to be allowed. Virgin

R-22 will continue to be available up to 2010. Recycled R-22 will be available R-22 will continue to be available up to 2010. Recycled R-22 will be available

up to 2015.

• HFCs are, as of today, not legislated against- their use should be restricted when possible.

New construction

• HFCs

Unfortunately HFCs, which were original introduced as substitutes for

ozone depleting CFCs are extremely powerful greenhouse gases, with a

global warming potential many thousand times larger than carbon

dioxide.dioxide.

• Natural substances

Natural substances can not be legislated against

Ammonia, apart from being toxic, would be the refrigerant of choice in

the majority of industrial applications.

Carbon dioxide and hydrocarbons are both good refrigerants.

Conclusions

• CFCs are history – no refrigerants allowed to be sold, supplied or

used.

• HCFCs are banned from being supplied in new refrigeration equipment. Still allowed to be used fore servicing existing equipment

until 2010, this date will be reviewed not later than 2008.until 2010, this date will be reviewed not later than 2008.

• HFCs still promoted as ‘best alternatives’ when a natural substance can not be readily used.

• Natural substances – carbon dioxide, ammonia, propane and cyclo-pentane, Free of legislation but possible safety considerations, toxicity,

flammability.

• Alternative technologies.

Halons and Halon replacements –

overview

• Halon family of gases.

• Replacements for Halons – marine applications.

• Legislation.

• Decommissioning requirements.

• IMO, Flag State, Montreal Protocol and European Union involvement.

Halons

• Halon 1211 (BFC) used in portable extinguishers & aircraft.

• Halon 1301 – (BTM) used in bulk or ‘flooded’ marine systems and petrochemical applications.

• Halons 2402 1011 – part of the same Halon group used for feedstock and for fire control.

• Critical use exception by (EC) regulation 2037

• IMO MSC 77/11/1 and especially Flag State involvement regarding continued critical use.

Replacements/Alternatives for Halon

1301

• Traditional

Detection and manual intervention

Water sprinkler systems – water mist ‘high fog’ system

Carbon dioxide, dry powder and foam

• Man-made gaseous agents

Inert gases – nitrogen, argon, carbon dioxide or mixtures

Halocarbon gases

Inert gas generation –aircraft only at present

• Fine solid particle technology

Still to be refined

Replacements for Halocarbon gases

• Both HFC and PFC gases had been developed

FE13 HFC 23 Triflouromethane

FE-125 HFC 125 Pentafluoromethane

FM-200 HFC 227ea Heptafluoropropane

FE-36 HFC 236fa HexafluoropropaneFE-36 HFC 236fa Hexafluoropropane

CEA-308 PFC-2-1-8 Perfluoropropane

CEA-410 PFC-3-1-10 Perfluorobutane

• Subsequently PFC gases have now been banned by IMO/SOLAS Chapter II-2, Reg. 10, 4.1.3.

• New alternatives such as Fluorinated Ketone are being developed and marketed under various Trade Names such as NOVEC 1230.

Legislation – effects

• The HFC alternatives have high global warming potential, from 2,900

to a staggering 11,700.

• The Kyoto Protocol will affect gases which have a high GWP.

• Within the EC the proposed ‘F-gas’ regulations may require any emissions from the whole family of halocarbon gases to be strictly

regulated.

• Some Flag State have individually restricted the continued use of Halon and they may also has some involvement with the Halon replacements.

Decommissioning

• Halon is still available on a worldwide basis to allow the continued safe

operation of cargo ships.

• IMO FP/Circ.27 ‘Halon banking and reception facilities’ lists the sites • IMO FP/Circ.27 ‘Halon banking and reception facilities’ lists the sites and limitations when Halon will be provided.

• The decommissioning date for EC Flag State countries was 31 December 2003. However recycled Halon is still available in a number of

Member States for critical use systems.

ANTI-FOULING COATINGS

Regulation and Certification

Anti Fouling Coatings, Regulation and

Certification

• Background

Antifouling coatings

Restriction of the use of antifoulants

• IMO AFS Convention and EU Regulation• IMO AFS Convention and EU Regulation

IMO Convention

Current status of the Convention

EC Regulation on antifouling systems.

• Survey, certification and inspection

IMO Guidelines

Survey, certification and inspection

Anti-fouling coatings

Antifouling paints are applied to the underwater parts of ships or structures

to keep the surfaces free of fouling in order to keep surfaces smooth and,

consequently, reduce fuel consumption and increase speed.

IMO AFS CONVENTION

International Convention on the Control of Harmful Anti-Fouling Systems on

Ships (AFS Convention) was adopted by an IMO Diplomatic Conference,

held in London in October 2001.

AFS Convention – Entry Into Force

Entry into force 12 months after 25 countries with not less than 25% of the

worlds GT to ratify the convention.

To date there are 8 countries with 9.36% of the world’s GT

AFS ConventionThe Convention:

Bans application of antifouling coatings containing organotin compounds from

being applied as biocides from 1 January 2003, and the active presence of

organotin compounds on ship’s hull surfaces from 1 January 2008.

EC AFS Regulation (EC 782/2003)

Same requirements as the AFS convention. Effective from 1 July 2003 for new

ships and from 1 July 2008 for existing ships.

Vessels changing to an EU flag must remove or seal TBT coating if the TBT

coating was/is applied after 1/7/2003

Surveys and Certification

Surveys and certification are required for:

Ships of 400 gt and above on international voyages.

Does apply to fixed and floating platforms, FSU’s and FPSO’s

Surveys

• MEPC Resolution 102(48):

Guidelines for survey and certification of anti-fouling systems onships adopted on 11 October 2002.

• MEPC Resolution 104(49):• MEPC Resolution 104(49):

Guidelines for brief sampling of anti-fouling systems on shipsadopted on 18 July 2003

• MEPC Resolution 105(49):

Guidelines for inspection of anti-fouling systems on ships adopted on 18 July 2003.

Document reviewShip’s details

Details of antifouling paints and coating specification (including sealer

coat)

Previous antifouling coat if not removed.

Survey

On-site inspection to verify compliance of the paint including.

Product identification and application witness

If necessary, sampling and testing of antifouling paints or coatings.

Certification

• Record of Antifouling System/Statement of Compliance.

• EU antifouling certificates.

• IMO antifouling certificates to be issued after the Convention comesinto force.

• Certificates remain valid until AFS changed.

Inspection by Port State Control

1. Initial inspection

Document checking

AFS certificate/Declaration of AFS

Record of AFSRecord of AFS

Brief sampling

2. More thorough inspection on documents and AFS

if there is any doubt.

BALLAST WATER

MANAGEMENTMANAGEMENT

Ballast Water Management

• Why manage ballast water and sediments and why have a

convention?

• The new Convention

• Ballast water management plans

What is the problem?

Every 9 weeks a new species is introduced somewhere in the

world

Every day, 7000+species of plants and animals are transported

in ballast.

Every year the world’s fleet moves 3-5 billion tones of ballast

around the world.

Why manage ballast water?

Why have a ballast water convention?

• The introduction of unwanted aquatic organisms via ships’ ballast water is

an internationally recognized problem.

• This introduction can have an effect on human health, cause damage to local marine life and local economies.

• The effects cost millions of dollars to deal with each year.

• The effects of unwanted organisms has been known for a considerable time.

• The United Nations Conference on Environment and Development (UNCED) in 1992, in Agenda 21 called on the IMO to take action to address

the transfer of harmful organisms by ships.

• The IMO have been discussing the issues involved and working towards a convention for more than 10 years.

The Convention

When will the Convention enter into force?

The convention will enter into force 12 months after at least 30 States, the

combined merchant fleets of which constitute at least 30% of the gross

tonnage of the world’s merchant shipping.

Which ships does the convention apply to?

The Convention will apply to all ships including submersibles, floating

craft, floating platforms, FSUs and FPSOs

The convention will not apply to:

Ships not designed to carry ballast water

Warship, naval auxiliary or other ship owned or operated by a State, only

on non-commercial service

Permanent ballast water in sealed tanks.

What does the convention require?

All ships will be required to:

• Carry out ballast water and sediment management on all

voyages.voyages.

• Have on board an approved ballast water management

plan and a ballast water record book.

• Ships of 400 gt and above are subject to surveys and

certification.

Ballast water managements options

• All ships will be required to:

Carry out Ballast Water Exchange (BWE) to the Carry out Ballast Water Exchange (BWE) to the

standard required by the convention (sequential or

flow through method) or

Use an approved ballast water treatment system

that meets the standards of the convention.

Ballast water exchange standards

• BWE to result to at least 95% volumetric exchange of BallastWater or

• Pumping through three times the volume of each Ballast Watertank is considered to meet the standard described above.

(Pumping through less than three times the volume may be

accepted, provided the ship can demonstrate that at least 95%

volumetric exchange is met.)

Treatment Systems standards

Discharge less than 10 viable organisms per cubic metre greater than or equal

to 50 micrometers in minimum dimension and less than 10 viable organisms

per mililitre less than 50 micrometers in minimum dimension and greater than

or equal to 10 micrometers in minimum dimension. And discharge of the

indicator microbes shall not exceed the specified concentrations.

Indicator microbes, as a human health standard, shall include:Indicator microbes, as a human health standard, shall include:

a. Toxicogenic Vibrio cholerae (01 and 0139) with less than 1 colony forming

unit (cfu) per 100 mililitres or less than 1 gram (wet weight) zooplankton

samples;

b. Escherichia coli less than 250 cfu per 100 mililitres;

c. Intestinal Enterococci less than 100 cfu per 100 mililitres.

Where can ballast water exchange be carried

out?

• At least 200 nm from the nearest land and in water at least 200 m in depth;

if this is not possible.

• As far from the nearest land as possible, and in all cases at least 50 nm from the nearest land and in water at least 200 m in depth.

• Countries may designate areas where ballast water exchange may be

undertaken inside these limits.undertaken inside these limits.

• A ship is not required to deviate from its intended voyage, or delay the voyage to comply.

• The master may decide not to carry out exchange:If it would threaten the safety of the ship crew or passengers; Because of

adverse weather, ship design or stress, equipment failure; Any other

extraordinary condition.

If not undertaken the reasons to be entered in the Ballast Water record

book.

What to do and when

Vessels constructed before 2009:

Ballast water capacity 1,500m3 to 5,500m3,

Exchange or Treatment until 2014;Treatment after 2014

Ballast water capacity less than 1,500m3 or more thanBallast water capacity less than 1,500m or more than

5,000m3,

Exchange or Treatment until 2016;Treatment after 2016.

Vessels to comply by the first intermediate or renewal

survey, which ever comes first, after the anniversary

date of delivery.

Vessels constructed in or after 2009

Ballast water capacity less than 5,000m3; Treatment

Vessels constructed between 2009 and 2012:

Ballast water capacity more than 5,000m3;Ballast water capacity more than 5,000m ;

Exchange until 2016; Treatment after 2016

Vessels constructed in or after 2012;

Ballast water capacity more than 5,000m3; Treatment

Do I have to do anything now?

For compliance with the Convention – NO

(except to plan ahead)

For compliance with national regulations –YES

For example Australia, New Zealand, Israel (Red

Sea), Canada, Chile, US (federal and individual

state).

Ballast water management practices

• Take precautions when ballasting

• Exchange Ballast

• Treat Ballast • Treat Ballast

• Control sediment built up

• Retain ballast on board.

• Discharge to shore reception facilities.

Precautions when ballasting

Minimizing the uptake of organisms by avoiding:-

• Areas where organisms occur

•• Algae blooms

• Shallow or sediment laden water

• Ballasting in darkness

• Avoiding unnecessary ballasting

Control Sediments

• Wash tanks regularly

• Remove sediments regularly

• Prevent sediment build up

Ballast Exchange

Three IMO recognized methods

• Sequential method

• Flow through method

• Dilution method

Water Ballast Exchange

Safety Issues

• Sloshing loads

• Bending moments

• Sheer forces

• Stability margins

• Weather Window

• Torsional stresses• Torsional stresses

• Tank venting

• Draft

• Propeller immersion

• Crew safety

Design Considerations

• Light and heavy ballast conditions

• Departure and arrival conditions

• Propeller immersion

�• Pumping capability

• Intact stability• Intact stability

• Bridge visibility

• Tank design

• Longitudinal strength

• Forward draught

• Dynamic Loads

• Ballast Sampling Arrangements

Ballast Treatment Systems

• FILTER

• HYDROCYCLONE

• THERMAL

• ULTRAVIOLET

• CHEMICAL

• GAS DOSING

Ballast Water Treatment

• Must be safe (For ship and crew)

• Must be environmentally acceptable

• Must be cost-effective

• Must work

• Must be approved

Approval Requirements

Treatment systems will be required to be approved in

accordance with IMO agreed guidelines.

The approval guidelines will be adopted in July 2005.

Ballast Water Treatment

• There are advantages and disadvantages to each type treatment

method.

• Current research seems to indicate that a combination of two or perhaps more methods may be the solution.

APPROXIMATE OPERATING COSTSAPPROXIMATE OPERATING COSTS

Per tonne of ballast (US cents)

• Sequential Exchange = 1

• Flow through = 2

• Heat = 2.5

• Filter = 0.5

• Cyclone = 0.3

• UV = 0.04

Ballast Water Management Plans

• A Ballast water Management Plan is to:

• Assist in the ship in complying with international regulations to minimizethe risk of the transfer of harmful aquatic organisms and pathogens in

ships’ ballast water and associated sediments.ships’ ballast water and associated sediments.

• Consider ship safety elements.

• Provide information to PSC/quarantine officers on the ship’s ballasthandling system and to confirm that ballast management can be effectively

planned.

• Include training on BWM operational practices.

Conclusions

• An early decision should be made on what BWM method(s) are to be used for new buildings.method(s) are to be used for new buildings.

• Ship design should take into account BWM

• A BWM plan should be produced for ballast exchange

operations to safeguard the ship

SHIP RECYCLING

IMO GUIDELINES

History of environmentalist involvement

• 1995 Dumping of Brent Spar

• Greenpeace turn attention to ships. Identify attention to • Greenpeace turn attention to ships. Identify attention to

ships. Identify & use Basle Convention to prevent export of

ships for scrap (toxic waste)

• 1999 P&O Nedlloyd targeted by Greenpeace for exporting 19 ships to China for scrap.

• Friends of the Earth stop the US ‘ghost ships’ being

dismantled at Able UK.

Traditional ship scrapping techniques

• Scuttling or abandonment.

• Primitive conditions.

• Little regard health & safety of workers

• Massive environmental pollution

• Low cost

Recent history

• Industry initiated development of guidelines for inventory of hazardous

materials onboard ships.

• Fed into IMO discussions and resulting IMO ‘Guidelines on Ship Recycling’ –adopted Dec 2003.

• The International Labour Organization (ILO) also developed Guidelines • The International Labour Organization (ILO) also developed Guidelines which apply to the safety & health of workers in recycling facilities – May

2003.

• The Basel Convention has published, ‘Technical Guidelines for the Environmentally Sound Management of the Full or Partial Dismantling of

Ships’ – December 2002.

• Difficulties of disposing of unwanted tonnage, exacerbated by EU regulations for accelerated phasing out single hull tankers.

IMO guidelines on Ship Recycling – A.962(23)

• To give “best practice”, adopted 05 December 2003.

• Voluntary guidelines – at present.• Voluntary guidelines – at present.

• Implications throughout ship lifecycle – existing ships &

new builds.

• Preparation of ship for recycling – ship recycling plan.

Scope of IMO Guidelines

• Ship design

Minimise use of hazardous materials

Design for recycling

• Through life inventory of potentially hazardous materials – Green Passport provided by shipyard.provided by shipyard.

Hazardous materials in ship’s structure and equipment

Operationally generated wastes

Stores

• Preparation for scrapping

Selection of recycling facilities

Preparation for recycling – plan

Minimise all residual oils and chemicals onboard

Major elements for owners – newbuildings

• Pre-newbuilding; contract review

Design out hazards – minimize the use of potential hazardous

materials

Finalized prior to final voyage.Finalized prior to final voyage.

• Newbuilding

Audit yard and sub contractor supply

Compile inventory and produce Green Passport

Promote waste reduction and/or regeneration

Major elements for owners – existing ships

• Green passport concept

It should contain ship details and an inventory of the potential

hazardous materials by type, location and quantity

Finalized prior to final voyage

• Disposal

Preparation for scrapping

Selection of suitable licensed facility – shipowner

Owners allowed to deliver ship with hazardous materials provided

the facility selected for recycling can deal with them.

Benefits of a Green Passport

• Provides a structured system to properly control hazardous

materials at newbuild and through life.

• Allows certification and reporting ability thus managing for

hazardous materials.hazardous materials.

• By identification of hazards it provides associated safety

benefits to those onboard.

• Invaluable tool to assess hazard management and hazard

management and hazard liability.

• Enhanced protection for environment.

Shipowner’s actions• Newbuilding program

Specify Green Passport for all newbuild contracts

Reduce or exclude hazardous materials in contract

Audit during construction

• Existing fleet

Compile inventory of hazardous material

Submit documentation for approval

Verification by survey and issue Green Passport

• Ships laid waiting to be scrapped

Green Passport

Preparation for scrapping

Advantages of early compliance with and

verification of Green Passports

• Future proofing against mandatory legislation

• Price structure

• Early identification of liability

For example tributyltin (TBT), polychlorinated For example tributyltin (TBT), polychlorinated

biphenyls (PCBs) and asbestos.

• Safety onboard

• Enhanced environmental profile

• Proactive stance

• Saleability

In conclusion – Future developments

• Tripartite IMO/ILO/BC meeting, February 2005

• Mandatory timetable

• Green Passport• Green Passport

• Licensed scrapping facilities

•

• Ready for scrap agreement

• Inevitable price structure shift

ENVIRONMENTAL

PROTECTION NOTATIONPROTECTION NOTATION

Environmental Protection notation

• Class society environmental rules

• Cover major operational pollutants

• Include design, equipment and operational aspects• Include design, equipment and operational aspects

• Goes beyond current environmental legislation

• Applies to new & existing ships

Structure of rule requirements

• Core requirements – mandatory

• Supplementary requirements – optional• Supplementary requirements – optional

• Fundamental requirements – mandatory

ISM, MARPOL & SERS

Core requirements

• Exhaust emissions (NOx SOx)

• Oil pollution

• Sewage

• Garbage• Garbage

• Ballast water

• Antifouling paints

• Fire-fighting agents

• Refrigerants

Supplementary modules

• Hull anti-fouling (A)

• Ballast water management (B)

• Grey water (G)

• NOx emissions (N)• NOx emissions (N)

• Oily bilge water (O)

• Protected oil tanks (P)

• Refrigeration systems (R)

• SOx emissions (S)

• Vapour emission control systems (V)

Sample requirements: Oxides of suphur

(SOx) exhaust emissions

• Core

Maximum sulphur (S) content 4.5% S

1.5% in IMO SOx Emission Control Areas

• Supplementary Maximum allowable fuel S content:

Maximum allowable fuel S content:

Gas oil = 0.2% m/m

Fuel oil = 1.5% m/m

Sample requirements: Refrigeration systems

• Core:

System design, operation and maintenance to minimize

refrigerant gas leakage;

Maximum allowable leakage = 10% total chargeMaximum allowable leakage = 10% total charge

• Supplementary:

Refrigerant gases restricted to those having

Ozone Depleting Potential (ODP) = 0

Global Warming Potential (GWP)<1950

Summary of design/equipment requirements

I

• General – compliance with all MARPOL annexes

• NOx – Interim Engine Air Pollution Prevention 9EIAPP certificate or Statement of Compliance – diesel engines above certificate or Statement of Compliance – diesel engines above

130Kw

• Refrigeration systems – leak detection system

• Fire-fighting systems – halons or halocarbons


II

• Oil pollution prevention – sludge & waste oil tankssufficient capacity to store oily wastes between ports. Oily

water separator to reduce oil-in-water content of bilge

water to 15 ppm or less.water to 15 ppm or less.

• Sewage – treatment system or holding tanks. Capacitysufficient for maximum number onboard. Various design

features (eg. Independent ventilation pipes). Statement of

compliance with the requirements of USCG 33 CFR 159

or MARPOL 73/78 Annex IV.


III

• Incinerators – where fitted, certificate of compliance with

requirements of IMO resolution MEPC 76(40)

• Hull antifouling – hull coatings must not contain tributyl tin

(TBT)

• Ballast water – incorporate features to help reduce need to

take up ballast water & help cleaning of ballast tanks to

remove sediments (eg. IMO Design suggestions for ballast

water & sediment management options in new ships)

Summary of operational procedures

• Oil fuel management for SOx emissions control

• Refrigerant management

• Oil pollution prevention measures

• Garbage management

• Sewage treatment & discharge control

• Operational measures to minimize transfer of non-native

organism in ballast water

• NOx emission control, if applicable

Approval process

• Plan & document review

• Initial survey (and audit)• Initial survey (and audit)

• Assignment of EP notation

• Annual and renewal surveys

Which ships?

• Mainly new builds, some existing ships

• Changing profile of owners and ships seeking EP notation

• Approx 170-180 appropriate completed or in hand

Statistics: Ships with EP notation (or undergoing

approval)approval)

Tankers 48%

Container ships 24%

LNG ships 8%

Naval vessels 7%

Cruise/passenger ro-ro 6%

Bulk carriers 2%

Private yachts 1%

Other 3%

How can Environmental Protection notation

benefit owners?

• Improves public relations

Provides evidence of environmentally responsibility to public,

customers and government

• Reduces likelihood of environmental incident• Reduces likelihood of environmental incident

Design for improved environmental performance

Operating procedures help maintain high environmental

standards

• Helps “future proof” your investment

Rules in line with international legislative developments

marine environmental protection legislation

Documents