Enforcement of low sulpher requirements in the low lands

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M.C. Vink Enforcement of low sulpher requirements in the low lands 19 oktober 2007

Prevention of pollution by ships MARPOL Annex VI EU Directive 2005/33/EC*, as regards the sulphur content of marine fuels. * EU Directive 2005/33/EC amends Directive 1993/12/EEG and 1999/32/EG

Why Against air polution by Sox Yellow / brown layer of smog above sea PM Acid rain Damage to our forests

10000 9000 8000 7000 6000 5000 4000 3000 2000 1000 0 SO 2 -emissions 2000-2030: land-based vs. shipping (thousand tonnes) EU25 Sea 2000 2005 2010 2015 2020 2025 2030 www.stichtingdenoordzee.nl

Marpol Annex VI In force from second of January in NL Annex VI for all ships! Ships >400 GT: An Int. Air Pollution Prevention Certificate (IAPP) if > 400 GT Ships <400 GT: The administration may establish appropriate measures to ensure that the applicable provisions of this annex are complied with.

Emission of Sulpher oxides (Sox) From the 19th of May 2005 any fuel used on board ships shall not exceed 4,5% m/m sulphur SECA s Within SOx Emission Control Areas (SECA): Any fuel used on board ships shall not exceed 1,5% m/m sulpher Approved exhaust gas cleaning system Baltic Sae from the 19th of May 2006 North West European waters from the 21th of November 2007 The definitions of the area s Baltic Sea and North West European waters as defined in Reg 1.11 of Annex I

7 Annex VI of MARPOL 73/78 Definition of the SECA South of 62 0 N Mongstad Bergen East of 4 0 W 57 0.44.8 N North Sea Baltic Sea Falmouth East of 5 0 W

Ships entering a SECA Example ship with day tank capacity of 20m3. With a content of 15 m3, 5m3 FO and 1,3% Sulphur is supplied: 20m3 of which ¾ HFO 4,0% and ¼ HFO 1,3%: total Sulphur = 3,33% 20M3 of which ¾ HFO 3,33% and ¼ HFO 1,3%: total Sulphur = 2,87% 20m3 of which ¾ HFO 2,87% and ¼ HFO 1,3%: total Sulphur = 2,53% After 7 times pumping the Sulphur content is still to high (1,64). For a ship of about 10000 GT it is two days sailing!

Fuel system example

BDN Bunker Delivery Note: Name and IMO Number of ship, date and name and address of fuel supplier, the product and quantity, density and % of Sulpher min. 3 year on board Accompanied with a sample Sample one year on board Declaration of the fuel supplier oil supplied is in conformity with Regulations

EU Directive 2005/33/EC In force from 19 may 2005 EU Directive concerning HFO in line with MARPOL Annex VI: Same requirements of sulphur 1,5% en 4,5% Same SECA s However date of coming into force are different: SECA Baltic Sea per 11-08-2006 SECA North West European waters per 11-08-2006

PSCC Instruction 38/2005/09 Initial inspection: Documentation equipment ship (IAPP, IEAPP s, Technical Files) Bunker Delivery Notes and associated samples Detailed inspection: Fuel sample Check log-book

Sampling The Laboratory of SGS take samples, take care of transport and analyses Reports within two hours Region's Rotterdam, Amsterdam en Vlissingen Monday to Saturday

MDO Service tank drain fuel filters Hp fuel pumps filter MDO Settling tank drain MDO separator Sludge tank Separator As close as possible to the engines MDO bunker Sludge tank

MARPOL Annex VI Specified Sulphur Limit (%m/m) Limits Sulphur test method Lower limit ISO 8754:2003 Upper limit 4.50 4.28 4.72 1.50 1.42 1.58 0.20 0.18 0.22 0.10 0.09 0.11

PSC Port state action in response to alleged contraventions %S > 1,5 and BDN < 1,5 Rectify before departure %S > 1,5 and BDN > 1,5 Ground for detention, rectify before departure and Major Non Conformity Port state send report of violation to the flag state for appropriate action

Quality Fuel oil quality Register of local suppliers Bunker state take action against suppliers if fuel does not comply with BDN Bunker state inform IMO of all cases where fuel suppliers have failed to meet the requirements Flag/Port state inform bunker state in case of non compliance

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