Global Management and Requirements to Reduce Pollution from Ships Especially in SECA Area

Global Management and Requirements to Reduce Pollution from Ships Especially in SECA Area Bahram Shomali Pour 1, Nasser Saidi 2, Maryam Taghinezhad Fard 3 1 M.SC. Student of Marine Transport Engineer, Khoramshahr Marine Science & Technology University (KMSU) 2 Master Assistant of faculty Economic & Management, Khoramshahr Marine Science & Technology University (KMSU) 3 Bachelor Student of commercial Management, Field of Port, Khoramshahr Marine Science & Technology University (KMSU) Abstract - On 10 October 2008 the Marine Environment Protection Committee (MEPC) of the International Maritime Organization (IMO) unanimously adopted the revised Annex VI to MARPOL 73/78 (International Convention for the Prevention of Pollution from Ships), which places restrictions on nitrogen and sulphur oxides emissions from ship traffic. Lowering the sulphur content in fuels will also be a way to reduce emissions of particulate matter from shipping. The subject of this paper was developed by ship owners and Administrations to help seafarers onboard in their work to understand and make use of the regulations of MARPOL Annex VI which is in force since 19 May 2005 with corresponding European legislation. So this paper can serve as a proactive approach to prevent illegal air emissions or possible violations from ships. Although ships are the most effective mode of transport, the political debate about emissions from ships is still very intensive. According to various statistics ships are responsible for 2% of Carbon dioxide emissions while carrying 90% of international goods, and also Sulphur Oxide emissions account to around 4% world wide. Nitrogen Oxide emissions from ships are responsible for 7% of world wide emissions. Heavy Fuel Oil is often used on board of ships as fuel. Keywords: marine environment, ship, sulphur Introduction Large ships such as container ships, tankers, bulk carriers, cruise ships, and Lakers are significant contributors to air pollution in many of our nation s cities and ports. There are two types of diesel engines used on large ships: main propulsion and auxiliary engines. Auxiliary engines on large ships typically range in size from small portable generators to locomotive-size engines. The aim of the IMO is to reduce emissions from ships by a switch from heavy fuel oils to light fuel oils. The new rules would place restrictions on nitrogen and sulphur oxides (NOx and SOx) emissions from ship traffic into the atmosphere and as fallout into the sea. Lowering the sulphur content in fuels is also a way to reduce emissions of particulate matter from shipping. The regulations would help reduce the harmful effects of emissions on human health and the marine environment, and would increase navigational safety. The new Annex enters into force Corresponding author; Tel: +989361975396 E-mail address: bahram.shomalipour@yahoo.com 219

on 1 July 2010, in accordance with the tacit acceptance procedure of the MARPOL 73/78 Convention. The sulphur content of fuel will fall in the special areas (SECA = Sulphur Emission Control Area), which are the Baltic Sea, the North Sea and the English Channel, from 1.5% to 1% from 1 July 2010, and to 0.1% from 1 January 2015. Globally, the highest permitted sulphur content of fuel will fall, as from 1 January 2012, from 4.5% to 3.5%, and to 0.5% from 1 January 2020. The use of sulphur scrubbers will still be allowed, so that the fuel grades currently in use on vessels fitted with them can also be used [1]. Under the new global standards, NOx emissions will be reduced, and the fuel sulfur cap will drop to 5,000 ppm in 2020 (pending a fuel availability review in 2018). Under the new geographic standards, ships operating in designated ECA s will be required to use engines that meet the most advanced technology-forcing standards for NOx emissions beginning in 2016, fuel with a sulfur content not exceeding 10,000 ppm in the first phase of the program, and 1,000 ppm in the second phase of the program. Documents describing the amendments and the amendment process are available below. Sulphur Emission Control Area (SECA) Given the requirements for all ships as contained in MARPOL Annex VI, Regulation 14, to be using 1.5% sulphur fuel oil on entering any SECA, the following supplies an outline or guide for fuel changeover in order to meet the requirements of these Regulations. This document is not intended to be specific for all vessels or replace the procedures as specified in the ship s ISM manual for this procedure. Before entry it is assumed that the vessel has sufficient low sulphur bunker fuel available for the total period that the vessel will be in the SECA. Evidence of this bunker fuel will be needed in the event of a port State inspection and this will consist of the Bunker Deliver Note (BDN) complying with the requirements and details as shown in Appendix V of MARPOL Annex VI [1]. At the inception of the fuel changeover process it is recommended that the content and tonnage of fuel in all bunker tanks onboard is recorded in the engine room log book together with the date, time and position of the vessel at the commencement of the procedure. If the ship is equipped with two day or service tanks then the time requirement for the procedure will be very much reduced. It is assumed that one Day or Service tank will contain higher sulphur heavy fuel oil (HFO) whereas the other is already filled with the required 1.5% sulphur fuel oil. Thus, the whole procedure will only require the isolation of the feed from the heavy fuel oil service tank and the flushing of the feed pipeline to the differing engines from the Low Sulphur day or service tank [2]. If the ship is equipped with only one day or service tank then flushing of the system will take a very much longer period. The procedure required could consist of: Reducing or emptying as far as is possible the settling tank of the previous HFO Flushing the pipeline to the settling tank and filling the settling tank with 1.5% sulphur fuel. Reducing or emptying as far as is possible the day or service tank. Flushing the connecting pipeline from the settling tank to the service or day tank with 1.5% fuel from the settling tank. Filling the service tank with low sulphur fuel and commence use of the low sulphur fuel before entry to that the feed pipelines to the engines are fully flushed. It is suggested from the limited experiences so far reported that this whole procedure could take hours if not longer whereas with the two service/day tank scenario it would be approximately 12 hours. 220

SECA Areas in force to date 1. Baltic Sea came into force on 19 May 2005 2. North Sea and English Channel came into force on 11 August 2007 Figure 1: Sulphur Emission Control Area (SECA) Fuel Types There are two types of bunker fuel oil: Residual fuel available in varying viscosities and high and low sulphur variants Distillate fuel - marine diesel & gas oil Residual fuels are a mix of refinery residual fuel and distillates blended to meet specification requirements. Distillate Fuel (which is product obtained by condensing the vapours distilled from petroleum crude oil or its products) comes in two variants and again, both are available with varying levels of sulphur content: Marine Gasoil (MGO) clear and not containing any residual component Marine Diesel Oil (MDO) essentially a distillate fuel which may contain a small amount of residual component [3]. Change Over Procedures: Upon entry into the SECAs the ships crew has to ensure that for any fuel used on board the maximum sulphur content is 1.5%. This change over procedure incorporates the main and auxiliary diesel engines and also auxiliary equipment as marine steam boilers and Inert Gasplants. Emergency generators and lifeboat engines are exempted. The ship normally is equipped with a heavy fuel oil system with one day tank system or two day tanks. If the ship has two day tanks than one day tank is filled with high sulphur heavy fuel oil and the other is filled with low sulphur heavy fuel oil. The level of filling in the low sulphur tank has to be sufficiently high before changing from one to the other tank to avoid a shortage of fuel 221

in case of separator or fuel problems. Before entering the SECA the fuel supply has to be changed from the high sulphur to the low sulphur tank and has to be completed in advance before entering the SECA. The necessary records of the fuel change over shall be made in the log book or into a separate fuel change over bunker record book [4]. In case of a one fuel system with one day tank, the preparation of low sulphur heavy fuel oil has to start well in advance before entering the SECA. The preparation time for the mixing of low and high sulphur fuel has to be pre-calculated to ensure that the sulphur limit of 1.5% is reached before entering the SECA. For this calculation, computer files (e.g. EXCEL-files from fuel oil suppliers) or approved change over manuals (e.g. from classification societies) can be used. Depending on the sulphur content of the fuels and the tank capacities the mixing time can be up to 40 hours or even longer. Changing back to High Sulphur Fuel Oil (HSFO) is allowed only after leaving the SECA. Again the relevant records shall be made into the appropriate ships log book when leaving the SECA. Please note that the Total Base Number (TBN) of the lubrication oil may have to be adjusted when using Low Sulphur Fuel Oil (LSFO) [5]. Port State Control (PSC) Inspections During port State Control Inspections the ship s crew has to be prepared to show on demand to the PSC inspectors the Bunker Delivery Note, the Fuel Oil Samples and the documentation of the fuel change over procedures in the engine log book or the fuel change over bunker record book. Furthermore it has to be ensured that enough low sulphur fuel oil is on board to enter the SECA boarder before leaving the port of PSC control. Otherwise the ship may be detained or may be forced to bunker low sulphur fuel in that port [6]. IMO Begins Work on Air Pollution At IMO, the Marine Environment Protection Committee (MEPC) in the mid-1980s had been reviewing the quality of fuel oils in relation to discharge requirements in Annex I and the issue of air pollution had been discussed [7]. In 1988, the MEPC agreed to include the issue of air pollution in its work programme following a submission from Norway on the scale of the problem. In addition, the Second International Conference on the Protection of the North Sea, held in November 1987, had issued a declaration in which the ministers of North Sea states agreed to initiate actions within appropriate bodies, such as IMO, "leading to improved quality standards of heavy fuels and to actively support this work aimed at reducing marine and atmospheric pollution" [8]. At the next MEPC session, in March 1989, various countries submitted papers referring to fuel oil quality and atmospheric pollution, and it was agreed to look at the prevention of air pollution from ships - as well as fuel oil quality - as part of the committee's long-term work programme, starting in March 1990. In 1990, Norway submitted a number of papers to the MEPC giving an overview on air pollution from ships. The papers noted: Sulphur emissions from ships' exhausts were estimated at 4.5 to 6.5 million tons per year - about 4 percent of total global sulphur emissions. Emissions over open seas are spread out and effects moderate, but on certain routes the emissions create environmental problems, including English Channel, South China Sea, Strait of Malacca. Nitrogen oxide emissions from ships were put at around 5 million tons per year - about 7 percent of total global emissions. Nitrogen oxide emissions cause or add to regional problems including acid rain and health problems in local areas such as harbours. 222

Emissions of CFCs from the world shipping fleet were estimated at 3,000-6,000 tons - approximately 1 to 3 percent of yearly global emissions. Halon emissions from shipping were put at 300 to 400 tons, or around 10 percent of world total. NOx Emission Standards NOx emission limits are set for diesel engines depending on the engine maximum operating speed (n, rpm), as shown in Table 1 and presented graphically in Figure 1. Tier I and Tier II limits are global, while the Tier III standards apply only in NOx Emission Control Areas [8]. Table 1: MARPOL Annex VI NOx Emission Limits Tier Date NOx Limit, g/kwh n < 130 130 n < 2000 n 2000 Tier I 2000 17 45 n -0.2 9.8 Tier II 2011 14.4 44 n -0.23 7.7 Tier III 2016 3.4 9 n -0.2 1.96 In NOx Emission Control Areas (Tier II standards apply outside ECAs) Figure 2: MARPOL Annex VI NOx Emission Limits Tier II standards are expected to be met by combustion process optimization. The parameters examined by engine manufacturers include fuel injection timing, pressure, and rate (rate shaping), fuel nozzle flow area, exhaust valve timing, and cylinder compression volume. Tier III standards are expected to require dedicated NOx emission control technologies such as various forms of water induction into the combustion process (with fuel, scavenging air, or incylinder), exhaust gas recirculation, or selective catalytic reduction. 223

Engines are tested using distillate diesel fuels, even though residual fuels are usually used in real life operation. Further technical details pertaining to NOx emissions, such as emission control methods, are included in the mandatory NOx Technical Code, which has been adopted under the cover of Resolution 2. Sulfur Content of Fuel Annex VI regulations include caps on sulfur content of fuel oil as a measure to control SOx emissions and, indirectly, PM emissions (there are no explicit PM emission limits). Special fuel quality provisions exist for SOx Emission Control Areas (SOx ECA or SECA). The sulfur limits and implementation dates are listed in Table 2 and illustrated in Figure 2 [8]. Table 2: MARPOL Annex VI Fuel Sulfur Limits Date Sulfur Limit in Fuel (% m/m) SOx ECA Global 2000 1.5% 2010.07 4.5% 2012 1.0% 2015 3.5% 2020 a 0.1% 0.5% a - alternative date is 2025, to be decided by a review in 2018 Figure 3: MARPOL Annex VI Fuel Sulfur Limits Heavy fuel oil (HFO) is allowed provided it meets the applicable sulfur limit (i.e., there is no mandate to use distillate fuels). Alternative measures are also allowed (in the SOx ECAs and globally) to reduce sulfur emissions, such as through the use of scrubbers. For example, in lieu of using the 1.5% S fuel in SOx ECAs, ships can fit an exhaust gas cleaning system or use any other technological method to limit SOx emissions to 6 g/kwh (as SO 2 ). 224

Fuel Prices According to the expert estimates of the member companies of the Finnish Oil and Gas Federation, prices for low sulphur (light) fuel grades are and will be higher than the price for heavy fuel oil currently being used. This being the case, the fuel and vessel running costs for ships operating in the current special areas, i.e. the Baltic Sea, the North Sea and the English Channel, will rise considerably as the provisions on sulphur content of 0.1 % in the revised MARPOL 73/78 (International Convention for the Prevention of Pollution from Ships) Annex VI enter into force in 2015. This will also affect global navigation when the global switch to fuel with 0.5% sulphur content in 2020 or no later than 2025 takes place. The switch to light fuel oil (diesel or gas oil) will result in a very significant rise in costs as compared to those for heavy fuel oil now in use. It has proven difficult to assess the availability of fuel. At present, fuel availability should not be a great problem, as the growing demand will create a supply. The USA and Canada will present a proposal to the IMO/MEPC in July 2009 to have the sea areas of these countries, which extend 200 nautical miles from their coastlines, designated as special areas with regard to the new sulphur content regulations. When light fuels start to be used worldwide, the oil industry will have to increase its refining capacity considerably to meet the rise in demand for light fuel grades. The results of interviews with experts suggest that increased fuel costs will, in time, be incorporated in their entirety in sea freight costs, which means that sea freight costs will increase considerably when the tighter regulations on sulphur content take effect in 2015. Rising freight costs will particularly affect export- and/or import-oriented sectors, such as the metal and forest industries. The total fuel consumption for ships bound for Finland has been estimated on the basis of two scenarios for consumption in 2007, where maximum consumption is 2.6 million Tones (scenario 1) and minimum consumption is 1.8 million tons (scenario2). The estimate is that if vessels bound for Finland were to switch from heavy to light fuel in this case gas oil with a maximum sulphur content of 0.1% - the following additional costs would be incurred given the differential in prices for fuel grades: 1) At 111 euros per ton the maximum would be 273 million euros and the minimum 190 million euros. 2) At 480 euros per ton the maximum would be 1.182 million euros and the minimum 823 million euros. These calculations do not take account of how much the additional costs would be if long-haul carriers (bound for destinations outside the SECA areas) also had to use low sulphur fuel outside the SECA areas for technical reasons. Neither do they take account of the savings in fuel costs through the possible use of sulphur scrubbers, adapted to deal with the conditions in the Baltic Sea [9]. The calculations made in this report are of a type that can serve as a good basis and starting point in the future when the figures are being updated in the light of new information, estimates and assessments. Greenhouse Gas Emissions MARPOL Annex VI, Chapter 4 introduces two mandatory mechanisms intended to ensure an energy efficiency standard for ships: (1) the Energy Efficiency Design Index (EEDI), for new ships, and (2) the Ship Energy Efficiency Management Plan (SEEMP) for all ships [2]. The EEDI is a performance-based mechanism that requires certain minimum energy efficiency in new ships. Ship designers and builders are free to choose the technologies to satisfy the EEDI requirements in a specific ship design. The SEEMP establishes a mechanism for operators to improve the energy efficiency of ships. 225

The regulations apply to all ships of and above 400 gross tonnage and enter into force from 1 January 2013. Flexibilities exist in the initial period of up to six and a half years after the entry into force, when the IMO may waive the requirement to comply with the EEDI for certain new ships, such as those that are already under construction. Other Provisions Ozone Depleting Substances. Annex VI prohibits deliberate emissions of ozone depleting substances, which include halons and chlorofluorocarbons (CFCs). New installations containing ozone-depleting substances are prohibited on all ships. But new installations containing hydrochlorofluorocarbons (HCFCs) are permitted until 1 January 2020 [1]. Annex VI also prohibits the incineration on board ships of certain products, such as contaminated packaging materials and polychlorinated biphenyls (PCBs). Compliance. Compliance with the provisions of Annex VI is determined by periodic inspections and surveys. Upon passing the surveys, the ship is issued an International Air Pollution Prevention Certificate, which is valid for up to 5 years. Under the NOx Technical Code, the ship operator (not the engine manufacturer) is responsible for in-use compliance. Conclusion Sulphur is everywhere in the atmosphere, the most common sulphur compounds being H2S, CH3SCH3, CS2, OCS and SO2. Of these, it is sulphur dioxide (SO2), obtained in the fuel combustion process in energy production and in industrial processes, that is not only harmful to human health but is also an important nutrient. Sulphur emission levels have been falling in SECA area, and this is observed everywhere in the country in the shape of lower sulphur dioxide content of the air and decreased sulphur fallout, both at background stations and traffic and industrial monitoring stations in cities. Currently the sulphur dioxide content can typically rise locally and for a short time when there is industrial disruption or malfunction. But in recent years sulphur dioxide levels in SECA area have remained under the limit values imposed to protect health. Gaseous SO2 oxidizes in the atmosphere to become sulphuric acid and sulphates, mainly via a hydroxyl radical, at a rate that is the equivalent of an average lifetime of around a week. Aqueous phase oxidation, e.g. in a cloud, is a much faster process. SO2 very effectively passes out of the atmosphere through a process of dry and wet deposition, so it also has a local fallout range, unlike NO2, which mainly passes out of the atmosphere only after it has converted into nitric acid or nitrates in atmospheric chemical reactions. The average lifetime of SO2 in the atmosphere is two days, while the lifetime of sulphate that results in the oxidation process is around five days. An important sulphur compound in the marine environment is dimethyl sulphide (DMS, CH3SCH3) produced from plant plankton, whose chemical lifetime in the marine environment is several days. References 1. MARPOL 73/78, International Convention for the Prevention of Pollution from Ships, Annex VI. 1997. 2. International Maritime Organization, Input from the four subgroups and individual experts to the final report of the Informal Cross Government/Industry Scientific Group of Experts, BLG 12/INF.10. 2007. 3. International Maritime Organization, Report on the outcome of the Informal Cross Government/Industry Scientific Group of Experts established to evaluate the effects of 226

the different fuel options proposed under the revision of MARPOL, Annex VI. MEPC 57/4/57. 2008. 4. International Maritime Organization, Prevention of air pollution from ships Sulphur monitoring for 2008, MEPC 59/4/1. 2009. 5. MARPOL 73/78, International Convention for the Prevention of Pollution from Ships, Annex I. 1978. 6. EU Directive of the European Parliament and of the Council of amending Directive 1999/32/EC as regards the sulphur content of marine fuels, 33/EC. 2005. 7. BIMCO Standard Bunker Contract. 8. Fortum, O., Raskaan polttoöljyn käyttöopas (Heavy Fuel Oil Guide), 2002. 9. Karvonen, T., Alternative calculations for container and ro-ro vessels, Aluskustannukset. 2007. 227