MARPOL ANNEX VI – REGULATIONS FOR PREVENTION OF AIR POLLUTION FROM SHIPS

Annex VI is divided into Four chapters.

Chapter I: Regulations 1-4, covers application, definitions, general exemptions and equivalents

Chapter II: Regulation 5-11, details the survey, certification and inspection controls to be   applied.

The International air pollution prevention (IAPP) certificate required to demonstrate compliance with the provisions of this annex is to be issued to ships of 400 gross tonnage and above which are engaged in international trade, following an initial survey. It will be subsequently be maintained by a series of annual (or intermediate) and periodic (every 5 years) surveys.

Chapter III contains the key operational regulations:

   Regulation 12: Ozone depleting substances.

   Regulation 13: Nitrogen Oxides

   Regulation 14: Sulphur Oxides

   Regulation 15: Volatile organic compounds

   Regulation 16: Ship board incineration

   Regulation 17: Reception facilities

   Regulation 18: Fuel oil Quality

   Regulation 19: Requirements for platforms and drilling rigs

Regulation 12:

  This includes but not limited to, following Ozone depleting substances.

  Fire fighting- Halon 1211, Halon 1301,Halon 2402/114B2

  Refrigerant- CFC-11, CFC-12, CFC-113,CFC-114, CFC-114

Under this regulation deliberate release of ODS during maintenance, servicing or repair is prohibited. No new systems containing ODS will be permitted other than those using hydro chlorofluorocarbons (HCFCs), which may be installed until January 1^st, 2020. Where ODS are to be removed from ships they are to be delivered to appropriate reception facilities.

Regulation 13, Oxides of Nitrogen  

These controls on NO_x emissions apply only to diesel engines over 130 kW installed on ship built on or after Jan 1^ST, 2000 along with engines which have undergone a ‘major conversion’ on or after Jan 1^st, 2000. Engines included with scope of this regulation will need to have a valid Engine International Air Pollution Prevention (EIAPP) certificates. 

Any diesel engines used solely for emergency purposes, are exempt.

The weighted brake specific NO_x emissions from the engines covered by regulation are to be with in the following limits based on the respective rated crank shaft speed:

Crank speed (n), rpm	NOX limit, g/kWh
Less than 130	14.36 g/kWh
130-1999	44 × n-0.23 g/kWh
2000 or more	7.668 g/kWh

In some cases, engines may actually have emission rates which are significantly above the respective limit value at some load points, particularly at lower loads. However by applying the weighting factors associated with the applicable load cycle the engines overall emission value is still within that required by regulation.

The measurement and calculation of NO_X value, engine certification and subsequent in- service verification must be undertaken in accordance with mandatory NO_x Technical Code.

Regulation 14, Oxides of Sulphur

Regulation 14 is primarily directed towards operational controls. These SO_X emission controls will apply to all forms of combustion machinery used on board, irrespective of their end use.

      A two tier approach is to be adopted to SO_X controls. At the global level, a sulphur cap value of 3.5 per cent m/m for all fuel oils will be introduced following the entry into force of the Annex. Further restrictions will apply when operating within certain environmentally sensitive areas, which will be declared ‘SO_X Emission Control Areas’. In these cases, the sulphur content of the fuel oils used must not exceed 1.0 per cent m/m.

      Where compliance with the requirements of the regulation is to be by operation on two grades of fuel, the change-over must occur prior to entry into a SO_X Emission Control Areas. The regulation requires that all fuel oil service system in use must be fully flushed of all fuels exceeding 1.0 per cent m/m sulphur content prior to entry into the designated areas, and that use of the substitute fuel oil must be maintained until after departure from the area. In addition, the volume of low sulphur fuel oil in each tank and the date, time and ship’s position when change-over was fully affected (both on entry and, by inference, on exit) must also be recorded in the ship’s log-book.

Regulation 15

Covers the standardization of vapour emission control systems (VECS) fitted on tankers to prevent the discharge of volatile organic compounds (VOCs) to atmosphere. This occurs primarily during loading of low pressure cargoes – crude oils and lower boiling point petroleum products such as naphta and gasoline. In those ports where the use of such systems is mandated, these VECS should be designed, certified and operated in accordance with IMO MSC circular 585.

 Regulation 16, Incineration

Although incineration has been used to comply with aspects of both Annex I (disposal of sludge from machinery system) and Annex V (garbage disposal), the resulting emissions from those operations were not previously directly controlled. A primary requirement of this regulation is that all incinerated installed on or after January 1^st, 2000 should comply with IMO MEPC resolution 76 (40), part of which specifies certain emission performance standards when operating with either an oil or solid waste; the composition of both is defined. Ships fitted with these incinerators will be required to have a copy of the manufacturers operating manual on board.

      The regulation requires that all personnel who operate incinerators are to be adequately trained. The incineration of following is prohibited in all cases:

•   MARPOL Annex I, II & III cargo residues and related contaminated packing materials.
•   PCBs – Polychlorinated biphenyls
•   Garbage containing more than traces of heavy metals ( i.e batteries)
•   Refined petroleum products containing halogens.

Although existing incinerators which do not meet the stipulated requirements can continue to be operated, the incineration of poly vinyl chlorides (PVC) will only be permitted in those units which comply IMO standards.

Regulation 18, Fuel Oil Quality

There are two main standards to this regulation. First incorporates the general requirements included with in ISO 8217-Specifications of Marine Fuels. This states that fuel oils supplied to ships for combustion shall be free from inorganic acid. Furthermore those fuel oils shall not include any added substance or chemical waste which: 

• Jeopardizes the safety of ships or affects the performance of machinery.  
• Is harmful to personnel; or 
• Contributes overall to additional air pollution.

The second part of this regulation ensures that the bunker note and control sample supplied to receiving vessel are accurate and truly describe the fuel oil as delivered. These requirements relate to both the general compositional requirements introduced by this regulation and the sulphur restrictions given in regulation 14. In meeting these requirements the information as stated by the supplier on bunker note is to be taken as prima facie evidence of intended compliance on part of the ship operator.

In addition to existing requirement covering flash point the bunker note must also state following information:

• Name and IMO number of receiving ship.
• Port at which fuel oil is supplied.
• Date of commencement of delivery.
• Name, address and telephone number of supplier.
• Product name.
• Quantity in tonnes.
•  Density at 15⁰C (kg/m³)
• Sulphur (percent m/m).

The supplier must provide a signed declaration to the effect that the F.O supplied is within the stipulated sulphur requirement and conforms to the compositional requirements. The control sample must be drawn correctly, essentially in accordance with the ISO Bunkering Protocol, sealed by the supplier, and signed for by the ship’s master or officer in charge of bunkering operation.

The bunker notes must be retained by both supplier and the receiving ship for a period of three years from date of supply. The control sample must be retained until the subject F.O has been substantially consumed, or for at least 12 months from date of delivery.

      Although Regulation 18 is entitled ‘Fuel Oil Quality’, it should only be seen in respect to area it covers. Quality issues which impact on usability such as stability, water or abrasive content and carbon residue are not addressed. Furthermore the purchaser will need to ensure that the fuel oil which has been delivered is of required grade, in terms of viscosity, density or for example of a particular ISO 8217 grade.

  Chapter Four:  Regulations for the energy efficiencies of ships
 All vessels of 400 GT and above are required to carry a Ship Energy Efficiency Management Plan (SEEMP) and be issued with an International Energy Efficiency (IEE) Certificate.

Posted By - Dennis Prakash.

References- Marpol, Exhaust emissions from combustion machinery by A.A Wright
IMAREST publication